The two Taxpayers agreed to consolidate their protests because both protests concerned the same issue. The Taxpayers were issued full refund denials by the Department to their requests for refunds of gross receipts tax for periods in 2014 to 2016, and each filed formal protests in response to the denials. The Taxpayers are business that provide dialysis services. Both claimed the deduction for gross receipts paid by a managed health care provider for commercial contract services. The Taxpayers argued that since the health care services were being performed by individuals that were health care practitioners the deduction would apply, even though the payments were being made to the business. The Department argued that the deduction the Taxpayers claimed was only available to individuals specifically included in the definition of a health care practitioner found in the statute. The Hearing Officer determined that based on previous decisions and Department regulation, the deduction was allowed for legal entities to claim if they were not certain types of health care facilities such as hospitals, hospices, or nursing homes, as specified in regulation. Since the businesses performing dialysis were legal entities that had employees or owners that were health care practitioners, and were not entities that were ineligible, the businesses were allowed to take the deductions. This having been decided, the Hearing officer denied the protest and ordered that the Department to pay the refunds.