Professional Service Organizations: A Critique of the Literature

In the seven years that have passed since the states began toauthorize doctors, lawyers, and other professional practitioners toorganize professional corporations and professional associations, the status of these new-style groups under the InternalRevenue Code has been the subject of a vast polemical literature. With few exceptions, the commentators have been sympathetic tothe view that professional service organizations are corporations as that term is defined by section 7701 (a)(3) of the Code;but the reasons offered by those who espouse this view are diverseand contradictory