W.W. Eure, M.D., Inc. - Page 11
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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
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Last modified: November 10, 2007