Mid-Del Therapeutic Center, Inc. - Page 3




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            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.                                                      







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Last modified: May 25, 2011