Hospital Corporation of America and Subsidiaries - Page 2

                                        - 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

Last modified: May 25, 2011