Hospital Corporation of America and Subsidiaries - Page 5

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          return (consolidated return) on Form 1120 with the Director of              
          the Internal Revenue Service Center at Memphis, Tennessee.                  
               Petitioners' primary business is the ownership, operation,             
          and management of hospitals.  Petitioners' hospitals provide                
          health care customarily provided by hospitals.  Most of                     
          petitioners' hospitals are acute care hospitals providing a                 
          facility, personnel, equipment, and medical supplies and                    
          pharmaceuticals needed to perform medical and surgical procedures           
          to treat sick or injured persons with various physical disorders.           
          Some of petitioners' facilities are psychiatric hospitals                   
          providing medical treatment to persons with mental or emotional             
          disorders and drug and alcohol dependency problems.                         
          Additionally, certain petitioners operate a variety of medically-           
          related businesses ancillary to petitioners' primary business.4             
          A fundamental component of petitioners' business philosophy is              
          the use of their combined purchasing power to obtain goods and              
          services at the lowest possible cost whenever practical to do so.           
               At the outset of its organization, HCA generally placed all            
          newly constructed or acquired hospitals in separate corporations.           
          In later years, in some cases, HCA placed all newly acquired or             
          newly constructed hospitals located in a particular State in a              


          4  See Hospital Corp. of Am. v. Commissioner, T.C. Memo. 1996-              
          105, for a detailed description of petitioners' hospital                    
          operations.  We incorporate herein our findings of fact contained           
          in that Memorandum Opinion.                                                 




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