PER CURIAM:
We affirm the orders of the Tax Court for the reasons stated in its decision. See V.R. DeAngelis M.D.P.C. v. Comm'r of Internal Revenue, 94 T.C.M. (CCH) 526 (2007), a copy of which is annexed to this opinion as an appendix. We have considered petitioners' arguments for a contrary result and found them to lack merit.
APPENDIX
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