Hospital Corp. of Am. v. Commissioner
United States Tax Court
Ps own, operate, and manage hospitals and related businesses. For taxable year ended 1987 and following years, certain Ps elected to use the nonaccrual-experience method provided pursuant to sec. 448(d)(5), I.R.C.
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Ps own, operate, and manage hospitals and related businesses. For taxable year ended 1987 and following years, certain Ps elected to use the nonaccrual-experience method provided pursuant to sec. 448(d)(5), I.R.C. On audit, R determined that those Ps could not use the nonaccrual-experience method to compute taxable income for either 1987 or 1988 because Ps sold medical supplies and because they could not determine the portion of their income attributable solely to the performance of services, or, alternatively, that if Ps are entitled to use the nonaccrual-experience method, they must use the…
1Opinion of the Court
Wells, Judge:
These cases were consolidated for purposes of trial, briefing, and opinion and will hereinafter be referred to as the instant case.1 Respondent determined deficiencies in petitioners’ consolidated corporate Federal income tax as shown below.
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Respondent also determined that the provision for increased interest pursuant to section 6621(c) applied. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
The issue to be decided in the…
2Cases cited36 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- Udall v. TallmanSupreme Court of the United States · 1965
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Rust v. SullivanSupreme Court of the United States · 1991
31 more not listed; retrieve them via the Exa API.
3Cited by32 opinions
- Woodral v. CommissionerUnited States Tax Court · 1999
- Hospital Corp. of Am. v. CommissionerUnited States Tax Court · 1997
- Greenberg Bros. P'ship 4 v. CommissionerUnited States Tax Court · 1998
- Osteopathic Med. Oncology & Hematology, P.C. v. CommissionerUnited States Tax Court · 1999
- Hall v. CommissionerUnited States Tax Court · 2010
27 more not listed; retrieve them via the Exa API.