- 2 - N. Jerold Cohen, Walter H. Wingfield, Stephen F. Gertzman, Amanda B. Scott, Reginald J. Clark, Randolph W. Thrower, Walter T. Henderson, Jr., and John W. Bonds, Jr., for petitioners in docket No. 28588-91. N. Jerold Cohen, Reginald J. Clark, Randolph W. Thrower, Walter T. Henderson, Jr., and John W. Bonds, Jr., for petitioners in docket No. 6351-92. Robert J. Shilliday, Jr., Vallie C. Brooks, and William B. McCarthy, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION WELLS, Chief 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: 1 The instant case involves many issues, most of which have been settled or decided already. Separate briefs of the parties were filed for each of the distinct categories of issues involved in the instant case. 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. We decided a depreciation issue in Hospital Corp. of Am. v. Commissioner, 109 T.C. 21 (1997). The instant opinion involves the last remaining issues for decision, which issues the parties have denominated the captive insurance or Parthenon Insurance Co. issues.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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