- 11 - He has a medical degree and received the special training required of radiation oncologists. We therefore find that petitioner satisfies the function test by having 95 percent or more of its corporate employees’ time spent providing healthcare directly to patients or in performing incidental services. In addition, the parties agree that petitioner satisfies the ownership test. Accordingly, petitioner is a qualified personal service corporation subject to the flat tax rate under section 11(b)(2) for the years at issue. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11Last modified: November 10, 2007