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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,
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Last modified: May 25, 2011