- 40 - 1985 and 1986 because the major portion of its expenditures during those years, namely, payments to FPCF and to AMH for patient care, constituted prohibited inurement to the board members. Petitioner also treats respondent's argument as an alternative and does not ask us to grant it exempt status during the aforesaid years if we conclude, as we do, that it lost such status at an earlier date. In this connection, petitioner points out that this issue is subsumed in the issues involved in docket No. 27403-92X wherein petitioner filed a petition, in response to respondent's action in respect of its request for exempt status after October 1, 1983, seeking a declaratory judgment that it was exempt in the years after the sale. We now turn to the question of whether petitioner, as a taxable entity during the years at issue herein, is entitled to certain deductions in computing its taxable income. These deductions are for amounts due FPCF, for grants to organizations and patient care and for a claimed net operating loss carryforward from its 1983 fiscal year. FPCF Petitioner had contingent liabilities to the FPCF at various times during its fiscal year 1983 and subsequent taxable years with respect to its hospital activities prior to the May 1983 sale. The deductibility of those liabilities to the extent that they became fixed or paid during the years is at issue herein.Page: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Next
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