- 5 - 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.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