Hospital Corporation of America and Subsidiaries - Page 44

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          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 reserves            





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