Acquisition in Affiliated Service Group Context

[Guest Darrell]

A doctor client will soon be creating a new service entity (Service Corp) with 5 other doctors. Each of the doctors will continue to maintain his own professional corporation (PC), and each PC will employ one or more nurses. The Service Corp will employ about 12 administrative, billing and shared employees. We clearly will have an affiliated service group consisting of the Service Corp and the 6 PCs. My question relates to the transition relief under 410(B)(6)© and 401(a)(26)(F). Will this be treated as an "acquisition or disposition" giving rise to the transition relief? If so, will the transition period begin on the date the doctors acquire their interests in the Service Corp or the date on which they are "regularly associated with the Service Corp in performing services for third persons?