- 3 - Background The stipulation of facts and the attached exhibits are incorporated herein. The stipulated facts are hereby found. Petitioner is an S corporation that was incorporated in Pennsylvania on May 22, 1991. At the time the petition was filed, petitioner’s principal place of business was in Malvern, Pennsylvania. Petitioner’s only business is providing consulting and surgical services to veterinarians. Dr. Sadanaga is petitioner’s sole shareholder and serves as its president, petitioner’s only officer. Since petitioner’s incorporation, all of its income has been generated from the consulting and surgical services provided by Dr. Sadanaga to Veterinary Orthopedic Services, Ltd. (Orthopedic). During the period at issue, Dr. Sadanaga spent at least 33 hours per week providing consulting and surgical services on behalf of petitioner. He performed surgeries at the Veterinary Referral Center in Frazer, Pennsylvania, and consulted with veterinarians in their offices or his home. Dr. Sadanaga is the only person with signature authority on petitioner’s bank account. Dr. Sadanaga handled all of petitioner’s correspondence and performed all administrative tasks on behalf of petitioner. Petitioner did not make regular payments to Dr. Sadanaga; rather, Dr. Sadanaga withdrew money from petitioner’s bank account at his discretion.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011