Hospital Corporation of America and Subsidiaries - Page 5

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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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