Legal Opinion

Hospital Corp. of Am. v. Commissioner

United States Tax Court

Decided July 24, 1997No. Docket Nos. 10663-91, 13074-91, 28588-91, 6351-92Published

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

HOSPITAL CORPORATION OF AMERICA AND SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Hospital Corp. of Am. v. Commissioner

Docket Nos. 10663-91, 13074-91, 28588-91, 6351-92

United States Tax Court

109 T.C. 21; 1997 U.S. Tax Ct. LEXIS 53; 109 T.C. No. 2;

July 24, 1997, Filed

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…

2Cases cited64 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Doris Berry, Personal Representative of the Estate of Lee F. Berry, Jr., Deceased v. City of DetroitCourt of Appeals for the Sixth Circuit · 1994
  3. James E. Threlkeld v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1988
  4. Threlkeld v. CommissionerUnited States Tax Court · 1986
  5. Clarence F. Davis v. Combustion Engineering, Inc.Court of Appeals for the Sixth Circuit · 1984

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