Hospital Corporation of America and Subsidiaries - Page 45

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          relating to premiums received by Parthenon from members of the              
          affiliated group on their consolidated returns for the years in             
          issue.  In the petitions filed in the instant case, petitioners             
          claim that Parthenon is entitled to be treated as an insurance              
          company for the years in issue, that petitioners are entitled to            
          deduct premiums they paid to Parthenon for insurance coverage for           
          those years, and that Parthenon is entitled to deduct the                   
          increase in its reserves associated with those premiums, in                 
          amounts of premiums not less than the following:                            
          Professional        Reinsurance                                             
          and General         of Workers'                                             
          Liability         Compensation                                              
          Year         Insurance           Insurance           Total                  
          1981         $15,571,167         $3,404,406       $18,975,573               
          1982          21,742,220          4,514,782        26,257,002               
          1983          17,630,680          5,364,185        22,994,865               
          1984          12,016,909          2,598,288        14,615,197               
          1985                                               36,796,826               
          1986                                               80,247,632               
          1987                                                    1                   
          1988                                                    1                   
          1Specific amounts were not stated in the petitions.                         
               Petitioners claim that overpayments of tax with respect to             
          the transactions with Parthenon result in tax in issue for the              
          years in issue as follows:                                                  
                    TYE               Increase (Decrease) in Tax                      
                    1981                    ($8,703,732)                              
                    1982                    (12,247,563)                              
                    1983                    (11,520,738)                              
                    1984                     (6,128,314)                              
                    1985                    (22,228,950)                              
                    1986                    (52,934,878)                              




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