- 9 - Petitioner also argues, on another ground, that the time the radiation technicians spent rendering services should not be considered in determining whether substantially all of its time is spent providing healthcare services. Petitioner urges us to ignore the time they spent because in its view radiation technicians are not among the professionals who provide medical services, according to the applicable regulations; namely, “physicians, nurses, dentists, and other similar healthcare professionals.” See sec. 1.448-1T(e)(4)(ii), Temporary Income Tax Regs., supra. We disagree. The enumerated list of professionals, i.e., physicians, nurses, and dentists, is not exclusive. The term “similar healthcare professionals” for these purposes conveys the need for advanced education and intellectual training “similar” to what is required of physicians, nurses, and dentists. Id.; see also Chickasaw Ambulance Serv., Inc. v. United States, No. C97-2094, (N.D. Iowa May 21, 1999). The regulations require that the corporation employ at least one healthcare professional who provides healthcare services to patients. Sec. 1.448-1T(e)(4), Temporary Income Tax Regs., supra. The regulations do not require that administrative and support services performed incident to such services be performed by corporate employees who are healthcare professionals. Healthcare services may be performed by non-healthcare professionals so long as at least onePage: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007