- 21 - “profit” to refer to the excess of the dentist’s receipts from his practice of dentistry over the costs of earning those receipts but without any reduction for the value of the dentist’s own services. The case, thus, reflects the unremarkable proposition that the return to an individual proprietor equals the receipts of the proprietorship less the expenses of the proprietorship, viz, the “profit” of the proprietorship. That proposition was useful to us in Bianchi because we assumed that (1) the proprietorship in question provided a service, (2) all of the proprietorship’s income resulted from the provision of that service, and (3) the proprietor was the sole service provider employed by the proprietorship. We were, thus, able to determine the value of the services provided by the individual proprietor to his proprietorship, and to use the result to test the reasonableness of the compensation paid to him by his wholly owned corporation. We cannot analogize petitioner to an individual proprietorship and employ the stated proposition to find that the value of the services provided by the shareholder surgeons to petitioner is equal to the profit made by petitioner (determined without any deduction for the compensation of the shareholder surgeons). One reason why we cannot do so is that the shareholder surgeons were not the only service providers employed by petitioner. There were also the nonshareholder surgeons,Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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