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made by Tsichlis and paid for by petitioner, their actual cost
has not been established. By 1982, the first floor of the
medical center was complete, including dental equipment,
ophthalmology equipment, and x-ray equipment. The second floor
facility was intended to be expanded by petitioner into a
physical therapy center; however, it was not completed. Most of
petitioner's expenditures went to the remodeling and purchase of
equipment located on the first floor. No further renovations
have been made at the medical center since 1983.
Petitioners maintained a Chase bank account in the name of
the medical center for the purpose of paying a $50,0003 equipment
loan provided by Chase. Dr. Rao transferred funds monthly from
his Midlantic money market account into the Chase account in
order to make the loan payments.
Dr. Rao entered into an agreement with Tilden Financial
Corp. for the lease of dental equipment in the amount of $38,180.
Petitioner was the chief individual responsible for
operating the medical center. He paid for all expenses incurred
in the operation of the medical center. Such expenses included
maintenance, x-ray supplies and film, gloves, and supplies for
all doctors and a nurse.
3 The record does not establish what part of the loan was
used to purchase equipment.
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