Hospital Corp. of Am. v. Commissioner
United States Tax Court
Ps own, operate, and manage hospitals and related businesses. For taxable years ended 1985 through 1987 Ps claimed depreciation deductions based on 5-year recovery periods for certain properties they placed in service during those years, which properties Ps claim constitute tangible personal property.
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Ps own, operate, and manage hospitals and related businesses. For taxable years ended 1985 through 1987 Ps claimed depreciation deductions based on 5-year recovery periods for certain properties they placed in service during those years, which properties Ps claim constitute tangible personal property. R determined that the properties constitute structural components of the buildings to which they relate and that the properties therefore must be depreciated over the same recovery periods as those buildings. Held: For purposes of assigning appropriate recovery classes or recovery periods to 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 follows:
TYE Deficiency
1978 . $2,187,079.00
1980 . 388,006.58
1981 . 94,605,958.92
1982 . 29,691,505.11
1983 . 43,738,703.50
1984 . 53,831,713.90
1985 . 85,613,533.00
1986 . 69,331,412.00
1987 . 294,571,908.00
1988 . 25,317,840.00
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule…
2Cases cited63 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Doris Berry, Personal Representative of the Estate of Lee F. Berry, Jr., Deceased v. City of DetroitCourt of Appeals for the Sixth Circuit · 1994
- James E. Threlkeld v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1988
- Threlkeld v. CommissionerUnited States Tax Court · 1986
- Clarence F. Davis v. Combustion Engineering, Inc.Court of Appeals for the Sixth Circuit · 1984
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3Cited by30 opinions
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- Deseret Management Corporation v. United StatesUnited States Court of Federal Claims · 2013
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