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practices through the corporate petitioner, a California
corporation. The stock of Roy, Inc. is owned 50 percent by Mohan
Roy and 50 percent by Vimal Roy.
During the years in issue, Mohan Roy performed hundreds of
open-heart surgical operations at four different hospitals in
Orange County, California; namely at Fountain Valley Medical
Center, Anaheim Memorial Hospital, Western Medical Center, and La
Mirada Hospital. Besides open-heart surgeries, he performed
vascular and thoracic surgeries at six other hospitals. In the
course of operative and postoperative management of patients, he
had to travel to and between the various hospitals. Mohan Roy
worked between 13 and 14 hours a day, approximately 300 days a
year, and traveled approximately 60-100 miles a day for business.
During the years in issue, Vimal Roy performed medical
services at three different hospitals, namely at Fountain Valley
Medical Center, Anaheim Memorial Hospital, and Newport Surgicenter.
She traveled approximately 100 miles a week, 50 weeks a year, for
business.
From the corporate office of Roy, Inc., Fountain Valley
Medical Center is approximately 10 miles, Western Medical Center is
approximately 5 miles, and La Mirada Hospital is approximately 20
miles. The corporate office of Roy, Inc. is next to Anaheim
Memorial Hospital. The distance between the Roys' residence in
Newport Beach to the corporate office of Roy, Inc., is
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Last modified: May 25, 2011