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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 one
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