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David C. May, for petitioner.
Grant E. Gabriel, for respondent.
OPINION
LARO, Judge: The parties submitted this case to the Court
without trial. See Rule 122. Petitioner petitioned the Court to
redetermine respondent's determination of a $50,515 deficiency in
its 1995 Federal income tax. The sole issue for decision is
whether petitioner, a professional service corporation, may use
the cash receipts and disbursements method (cash method) to
expense the drugs and ancillary pharmaceuticals (collectively,
chemotherapy drugs) used by it while providing chemotherapy
treatments to its patients. We hold it may. Unless otherwise
stated, section references are to the Internal Revenue Code as
applicable to 1995, and Rule references are to the Tax Court
Rules of Practice and Procedure.
Background
All facts are stipulated and are so found. The stipulation
of facts and exhibits submitted therewith are incorporated herein
by this reference. Petitioner's principal place of business was
in Clinton Township, Michigan, when it petitioned the Court.
Petitioner is a professional medical corporation that
provides osteopathic services, with a speciality in oncology
(mainly chemotherapy) and hematology. Petitioner's staff
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