- 44 - petitioners' hospitals qualified for reimbursement under the Federal Medicare program. To make that determination, Blue Cross was required to confirm that the premiums charged by Parthenon to petitioners were reasonable in light of comparable commercial rates, that both premiums and reserves were based on actuarial determinations, that premiums did not reflect a profit factor, that Parthenon was duly licensed and met appropriate criteria for insurance companies set out by the State of Tennessee, that it had adequate claims administration and adequate risk management, and that there were no loans or transfers of funds from Parthenon to any affiliated company other than payment of covered claims. For each of the years in issue, Blue Cross found that Parthenon met the required criteria. In audit reports issued for those years, Blue Cross specifically confirmed the reasonableness, prudence, and actuarial foundation of the premiums charged by Parthenon, including the additional premiums charged to fund deficiencies in the 1984-86 reserves. Tax Treatment Parthenon has been included in the consolidated returns filed by petitioners since it began business during 1977. Because of disagreement between petitioners and respondent as to the proper tax treatment of premiums HCA and the sister subsidiaries paid to Parthenon for earlier tax years petitioners did not claim a deduction for the increase in insurance reservesPage: Previous 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 Next
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