Hospital Corporation of America and Subsidiaries - Page 3

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               WELLS, Judge:  These cases were consolidated for purposes of           
          trial, briefing, and opinion and will hereinafter be referred to            
          as the instant case.1  Respondent determined deficiencies in                
          petitioners' consolidated corporate Federal income tax as                   
          follows:                                                                    
          TYE                       Deficiency                                        
          1978                     $2,187,079.00                                      
          1980                        388,006.58                                      
          1981                     94,605,958.92                                      
          1982                     29,691,505.11                                      
          1983                     43,738,703.50                                      
          1984                     53,831,713.90                                      
          1985                     85,613,533.00                                      
          1986                     69,331,412.00                                      
          1987                    294,571,908.00                                      
          1988                     25,317,840.00                                      
          Unless otherwise indicated, all section references are to the               
          Internal Revenue Code in effect for the years in issue, and all             

          1   The instant case involves many issues, some of which have               
          been settled or decided.  The issues remaining for decision                 
          involve matters falling into two reasonably distinct categories,            
          which the parties have denominated the MACRS depreciation issue             
          and the captive insurance or Parthenon Insurance Co. issues.  The           
          MACRS depreciation issue was presented at a special trial session           
          with two other distinct categories of issues that we previously             
          decided, and the captive insurance issues were severed for trial            
          purposes and were presented at a subsequent special trial                   
          session.  Separate briefs of the parties were filed for each of             
          the distinct categories of issues.  We decided tax accounting               
          issues in Hospital Corp. of Am. v. Commissioner, T.C. Memo. 1996-           
          105; Hospital Corp. of Am. v. Commissioner, 107 T.C. 73 (1996);             
          and Hospital Corp. of Am. v. Commissioner, 107 T.C. 116 (1996).             
          We decided an issue related to the sale of the stock of certain             
          subsidiaries to HealthTrust, Inc.--The Hospital Company in                  
          Hospital Corp. of Am. v. Commissioner, T.C. Memo. 1996-559.  The            
          Parthenon Insurance Co. issues will be addressed in a separate              
          opinion subsequently to be released.  The instant opinion                   
          involves the MACRS depreciation issue.                                      




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