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Nashville, Tennessee, on the date the petitions were filed. For
each of the taxable years involved in the instant case, HCA and
its domestic subsidiaries filed a consolidated Federal corporate
income tax return (consolidated return) on Form 1120 with the
Director of the Internal Revenue Service Center at Memphis,
Tennessee.
Petitioners' primary business is the ownership, operation,
and management of hospitals. In Hospital Corp. of Am. v.
Commissioner, T.C. Memo. 1996-105, we set forth a detailed
description of petitioners' hospital operations, which will not
be reiterated here. We incorporate herein our findings of fact
contained in that Memorandum Opinion.
During the taxable years in issue, petitioners constructed a
number of hospital facilities. Those hospital facilities consist
generally of 10 different categories, which the parties
denominate as follows: (1) Large Medical/Surgical Facilities;
(2) Small Medical/Surgical Facilities; (3) Ancillary Facilities;
(4) Radiology Facilities; (5) Small Psychiatric Facilities; (6)
Large Psychiatric Facilities; (7) Obstetrics Facilities; (8)
Ambulatory Surgery Facilities; (9) Patient Bed Facilities; and
(10) Ancillary II Facilities.
On their tax returns for taxable years ended 1985, 1986, and
1987, petitioners classified as tangible personal property
2 (...continued)
its name to Columbia/HCA Healthcare Corporation.
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