Hospital Corp. of America v. Commissioner
United States Tax Court
HCA was in the hospital management business in the United States. It operated hospitals owned by it or its domestic subsidiary corporations and operated other hospitals under management contracts entered into with the owners thereof. In 1973, HCA decided to pursue an opportunity to contract with the Royal Cabinet of the Kingdom of Saudi Arabia to manage the King Faisal Specialist Hospital in Riyadh, Saudi Arabia.
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HCA was in the hospital management business in the United States. It operated hospitals owned by it or its domestic subsidiary corporations and operated other hospitals under management contracts entered into with the owners thereof. In 1973, HCA decided to pursue an opportunity to contract with the Royal Cabinet of the Kingdom of Saudi Arabia to manage the King Faisal Specialist Hospital in Riyadh, Saudi Arabia. HCA formed a Cayman Islands corporation to negotiate and perform this management contract. HCA performed services for and made available to its Cayman Islands subsidiary its hospital…
1Opinion of the Court
Parker, Judge:
In docket No. 12988-78, respondent determined deficiencies in Federal income taxes of $6,789,289.25 for 1972 and $22,398,355.65 for 1973. In docket No. 13183-78, respondent determined deficiences as follows:
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All of the adjustments in the separate notices of deficiency issued to each of the petitioners in docket No. 13183-78, and all but one of the adjustments in the notice of deficiency issued in docket No. 12988-78, have been resolved by agreement of the parties. The issues remaining for decision concern the adjustment to foreign income. The questions presented…
2Cases cited57 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Gregory v. HelveringSupreme Court of the United States · 1935
- Lucas v. EarlSupreme Court of the United States · 1930
- Higgins v. SmithSupreme Court of the United States · 1940
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3Cited by46 opinions
- Cheshire v. CommissionerUnited States Tax Court · 2000
- Haag v. CommissionerUnited States Tax Court · 1987
- Estate of Gardner v. CommissionerUnited States Tax Court · 1984
- Northern Indiana Public Service Company v. Commissioner of Internal Revenue, Cross-AppelleeCourt of Appeals for the Seventh Circuit · 1997
- Eli Lilly & Co. v. CommissionerUnited States Tax Court · 1985
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