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TYE Deficiency
1978 $2,187,079.00
1980 388,006.58
1981 94,605,958.92
1982 29,691,505.11
1983 43,738,703.50
1984 53,831,713.90
1985 85,613,533.00
1986 69,331,412.00
1987 294,571,908.00
1988 25,317,840.00
Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
The issues to be decided are:
(1) Whether Parthenon Insurance Co. (Parthenon), a wholly
owned subsidiary of petitioner Hospital Corporation of America
(HCA), is an insurance company within the meaning of the Internal
Revenue Code; and
(2) if Parthenon is an insurance company, what portion of
its unpaid loss reserves and expenses are deductible pursuant to
section 832(c).2
2 In accordance with the holding of the Court of Appeals for
the Sixth Circuit in Humana Inc. v. Commissioner, 881 F.2d 247
(6th Cir. 1989), affg. in part and revg. in part 88 T.C. 197
(1987), petitioners seek deductions only for reserve additions
attributable to reserves for claims against Parthenon's sister
subsidiaries, and not for reserve additions attributable to
reserves for claims against HCA itself. Absent stipulation of
the parties to the contrary, our decision in the instant case is
appealable to the Sixth Circuit.
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