Hospital Corp. of Am. v. Commissioner
United States Tax Court
Ps own, operate, and manage hospitals and related businesses. For taxable year ended 1987, pursuant to sec. 448, I.R.C., Ps not already using an overall accrual method changed their method of accounting to that method. Also during 1987, HCAII, a wholly owned subsidiary of HCA, sold all of the stock of some subsidiaries that owned and operated hospitals and other facilities.
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Ps own, operate, and manage hospitals and related businesses. For taxable year ended 1987, pursuant to sec. 448, I.R.C., Ps not already using an overall accrual method changed their method of accounting to that method. Also during 1987, HCAII, a wholly owned subsidiary of HCA, sold all of the stock of some subsidiaries that owned and operated hospitals and other facilities. On audit, R determined that for certain of those subsidiaries (Category B Corporations) Ps had to include in income for taxable year ended 1987 the entire sec. 481, I.R.C., adjustment relating to the change in method of…
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. 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 under 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 for decision in the instant…
2Cases cited32 opinions
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3Cited by21 opinions
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