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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.
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