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c. Expenses
Both parties’ allocations of expenses to Dr. Snyder’s
collections for 1994 and Dr. Vaughan’s collections for 1995
consist of the salary paid to each plus one-tenth (one-fifth for
the one-half of the audit year during which each was employed) of
other expenses considered equally apportionable to the five
surgeons employed during each year.5 The parties differ,
however, as to whether certain of petitioner’s expenses were at
all allocable to Drs. Snyder and Vaughan. We accept respondent’s
proposed allocation of expenses as reasonable with the following
additional allocations: There should be a pro rata (one-tenth)
allocation of rent, repair and maintenance expense, depreciation
of office equipment (other than shareholder automobiles),
telephone expenses, and equipment lease expenses to the
nonshareholder surgeons’ collections.6 Thus, for the audit
5 Although respondent attempted to elicit testimony from
Dr. Mann that the nonshareholder surgeons might not have utilized
office space and staff to the same degree as the shareholder
surgeons, there is no evidence in the record that would enable
the Court to make a specific finding in that regard. We also
ignore as immaterial the fact that Dr. Ellis was employed for
only 6 months during 1995.
6 As noted, supra in our findings of fact, the
nonshareholder surgeons’ employment contracts obligated
petitioner to furnish its nonshareholder surgeons with “an
office, stenographic help, supplies, equipment, and such other
facilities and services * * * adequate for the performance of
* * * [their] duties.”
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