Hospital Corporation of America and Subsidiaries - Page 4

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                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated for trial pursuant to           
          Rule 91.  The parties' stipulations of fact are incorporated                
          herein by reference and are found as facts in the instant case.             
          In General                                                                  
               Petitioners are members of an affiliated group of                      
          corporations of which HCA is the common parent.  HCA was                    
          incorporated during 1960 under the laws of the State of Tennessee           
          as Park View Hospital, Inc.  During 1968, Park View Hospital,               
          Inc. joined with 11 other hospitals to form HCA.  After that                
          date, and through the years in issue, HCA's stock was publicly              
          held and traded on the New York Stock Exchange.3                            
               HCA maintained its principal offices in Nashville,                     
          Tennessee, on the date the petitions were filed.  For each of the           
          years involved in the instant case, HCA and its domestic                    
          subsidiaries filed a consolidated Federal corporate income tax              



          3  On Mar. 17, 1989, a group consisting of HCA key management               
          and certain outside investors acquired control of HCA and caused            
          it to purchase all of the stock held by the public shareholders,            
          and they then transformed HCA from a publicly held corporation to           
          a privately held corporation.  On Mar. 4, 1992, HCA again went              
          public and changed its name to HCA-Hospital Corporation of                  
          America.  On Feb. 10, 1994, HCA was merged with and into Galen              
          Healthcare, Inc., a subsidiary of Columbia Healthcare Corp. of              
          Louisville, Kentucky, and the subsidiary changed its name to HCA-           
          Hospital Corp. of America.  On that same date, the parent changed           
          its name to Columbia/HCA Healthcare Corporation.                            




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