- 10 - healthcare professional is employed to perform healthcare services. Moreover, incidental services may be performed by secretaries, administrative assistants, office managers, or other non-professionals. In addition, the taxpayer in Chickasaw proved that its emergency medical technicians (EMTs) could perform their jobs without high school diplomas, while petitioner fails to prove that its radiation technicians can perform their jobs without advanced education and intellectual training similar to what is required of physicians, nurses, or dentists. Petitioner also stipulated that radiation technicians are highly trained but failed to show what level and type of education is required of them. Moreover, even if petitioner’s radiation technicians were not healthcare professionals, the function test is applied by considering the activities of all a corporation’s employees. Sec. 1.448-1T(e)(4), Temporary Income Tax Regs., supra. Unlike Chickasaw, where the only employees of the corporate taxpayer were EMTs who could perform their services without a high school diploma, petitioner provides radiation therapy that only a doctor who has had special training in using radiation to treat disease can prescribe for cancer patients. Petitioner had such an employee, Dr. Farah.5 Dr. Farah is highly trained and educated. 5Petitioner also employed Dr. Eure, who is highly educated and specially trained, but he did not provide healthcare services during the years at issue.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007