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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.
Background
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
indicated.
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