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unconvincing the taxpayer's argument that the readership was
purchasing a service.
We also find the facts herein to be markedly different from
the facts presented in the various cases on this issue involving
contractors and subcontractors. In all of those cases where we
found the taxpayer was selling merchandise, the contractor's
services involved installation of products and the customers came
to the contractors to purchase the products as well as the
installation services. See, e.g., Thompson Elec., Inc. v.
Commissioner, T.C. Memo. 1995-292 (taxpayer was selling
merchandise in connection with a service when he installed
wiring, conduits, electrical panels, and lighting fixtures); J.P.
Sheahan Associates, Inc. v. Commissioner, T.C. Memo. 1992-239
(contractor's roofing materials were merchandise); Surtronics,
Inc. v. Commissioner, T.C. Memo. 1985-277 (electroplating metals
were merchandise). The customers of the taxpayers also could
have personally purchased the merchandise elsewhere and either
installed the merchandise themselves, if they had the time and
expertise to do so, or contracted with a third party to install
the merchandise for them. In the instant case, by contrast,
persons seeking chemotherapy treatment may not buy the drugs
elsewhere, and they may not apply the drugs themselves.
Respondent unduly focuses on the fact that petitioner listed
on the bills submitted to Medicare and private insurers the type
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