- 4 - Petitioner Petitioner, a Texas corporation, was organized in 1976 by Drs. Richard Ellis and Charles M. Mann, Jr. It is a personal service corporation. It provides pediatric surgical services in the area of Fort Worth, Texas. Pediatric surgery is a surgical subspecialty limited to surgical procedures on infants and children. During the audit years, petitioner employed approximately 20 individuals, including six pediatric surgeons. During those years, it maintained three offices. Petitioner’s patient base consists, primarily, of patients referred to petitioner by pediatricians. Petitioner’s employee surgeons perform almost all of their surgery at Cook Children’s Medical Center (the hospital), in Fort Worth, Texas. Petitioner also has an arrangement with the hospital to provide on-call surgical services in the hospital’s emergency room. Petitioner’s business is the only pediatric surgical business in the Fort Worth, Texas, area. Petitioner computes taxable income under the cash receipts and disbursements method of accounting. Petitioner has never declared a dividend. Shareholder Surgeons During the audit years, the shares of stock of petitioner were owned exclusively by individuals who were also employed by petitioner as surgeons. From January 1, 1994, through June 30,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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