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            
                                             for respondent.                          

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