United States Sixth Circuit

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HOSPITAL CORP. OF AM. & SUBSIDIARIES v. COMM'R OF INTERNAL REVENUE, 01-1810

The Tax Court's ruling in favor of defendant is affirmed where the Temporary Treasury Regulation at issue is a reasonable interpretation of the Internal Revenue Code Section 448(d)(5), and the court correctly found that Treasury Regulation 1.448-1(g) represents a permissible interpretation of Section 481(a) of the IRC.

Appellate Information

  • Decided 10/30/2003
  • Published 10/30/2003

Judges

  • Before:  MARTIN and ROGERS, Circuit Judges;  EDMUNDS, District Judge.

Court

  • United States Sixth Circuit

Counsel

  • For Appellant:
  • N. Jerold Cohen (argued and briefed), Walter H. Wingfield (briefed), Teresa W. Roseborough (briefed), Amanda B. Scott (briefed), Thomas A. Cullinan (briefed), Matthew J. Gries (briefed), Sutherland, Asbill & Brennan, Atlanta, GA, for Appellant.

  • For Appellees:
  • Teresa E. McLaughlin (briefed), Thomas J. Sawyer (argued and briefed), United States Department of Justice, Appellate Section Tax Division, Washington, D.C., for Appellee.