W.W. Eure, M.D., Inc. - Page 9

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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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