derived directly or indirectly

A professional corporation (PC1), whose voting shares have been held by Dr. A (a physician) and whose non-voting participating shares have been held equally by Dr. A and Spouse A (who has had no involvement in the practice) has applied earnings to build up a large portfolio of publicly-traded securities, which is managed by a financial institution with little involvement of the couple. However, on December 30 of Year 1, PC1 ceased carrying on its medical services business, on December 31, Spouse A acquired 50% of Dr.