W.W. Eure, M.D., Inc. - Page 2

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          corporation subject to a special flat income tax rate of 35                 
          percent under section 11(b)(2)1 rather than the graduated income            
          tax rates for corporations under section 11(b)(1).  We hold that            
          it is.                                                                      
               This case was submitted fully stipulated pursuant to Rule              
          122, and the facts are so found.  The stipulation of facts and              
          the accompanying exhibits are incorporated by this reference.               
          Petitioner’s principal place of business was Redlands,                      
          California, at the time it filed the petition.                              
               Werdna Wayland Eure, Jr., M.D. (Dr. Eure), is a medical                
          doctor who has been a licensed physician and surgeon in                     
          California since 1982.  Dr. Eure incorporated petitioner as a               
          California professional medical corporation in 1996.  Dr. Eure              
          has been petitioner’s sole shareholder since its incorporation.             
          Petitioner operated a radiation oncology treatment facility that            
          did business under the name Radiation Therapy Medical Group                 
          during the years at issue.                                                  
          Radiation Therapy                                                           
               Radiation is a kind of energy carried by waves or a stream             
          of particles.  Radiation emitted at sufficiently high levels by             
          special machines, which are aimed at tumors or areas of a                   

               1All section references are to the Internal Revenue Code in            
          effect for the years at issue, and all Rule references are to the           
          Tax Court Rules of Practice and Procedure, unless otherwise                 

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