- 3 - of business was in Oklahoma City, Oklahoma. Dr. D. Richard Ishmael, an oncologist, owns 100 percent of the stock of both Mid-Del and PC. PC is Dr. Ishmael’s personal service corporation, and Mid-Del is a subchapter C corporation owned and managed by Dr. Ishmael. During the relevant periods, petitioners operated medical clinics that purchased and used chemotherapy drugs (drugs) to treat patients with cancer and other illnesses. PC maintained an onsite pharmacy where the drugs purchased by both PC and Mid-Del were stored and where a pharmacist employed by PC mixed and prepared chemotherapy treatments for both clinics. Petitioners used approximately 85 different drugs to treat patients. With the exception of Mid-Del’s Federal income tax return for the taxable year 1993, both Mid-Del and PC used the cash method of accounting (cash method) for income tax purposes and consistently reported the drugs used in patient treatments as supplies and not as inventory. Mid-Del’s 1993 return, which originally was filed using the accrual method of accounting (accrual method), was amended to report income and expenses on the cash method after a revenue agent determined on audit that Mid-Del was required to use the cash method. It was a customary and accepted practice in the health care industry for health care practitioners to use the cash method.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011