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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.
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Last modified: May 25, 2011