Hospital Corporation of America and Subsidiaries - Page 1

                                   109 T.C. No. 2                                     

                               UNITED STATES TAX COURT                                

                   COMMISSIONER OF INTERNAL REVENUE, Respondent                       

               Docket Nos. 10663-91, 13074-91,     Filed July 24, 1997.               
          28588-91,  6351-92.                                                         

                    Ps own, operate, and manage hospitals and related                 
               businesses.  For taxable years ended 1985 through 1987                 
               Ps claimed depreciation deductions based on 5-year                     
               recovery periods for certain properties they placed in                 
               service during those years, which properties Ps claim                  
               constitute tangible personal property.  R determined                   
               that the properties constitute structural components of                
               the buildings to which they relate and that the                        
               properties therefore must be depreciated over the same                 
               recovery periods as those buildings.                                   
                    Held:  For purposes of assigning appropriate                      
               recovery classes or recovery periods to the properties                 
               to determine allowable depreciation deductions pursuant                
               to sec. 168, I.R.C., tests developed under prior law                   
               for purposes of the investment tax credit are                          
               applicable to decide whether the property constitutes                  
               tangible personal property.                                            

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