Mahendra K. Tandon - Page 4

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          Tandon was petitioner's father.  He died in 1987.  Petitioner has           
          a sister named Indira Khana (Ms. Khana).                                    

          Petitioner's Medical Practice                                               
               Petitioner was a medical doctor and conducted his medical              
          practice out of a clinic located at 4620 St. Clair Avenue,                  
          Cleveland, Ohio (St. Clair property).  Petitioner's medical                 
          practice primarily consisted of workers' compensation                       
          examinations, the treatment of industrial accidents and personal            
          injuries, and consulting with attorneys on medical malpractice              
          cases.  During 1985, 1986, and 1987, petitioner operated his                
          medical practice as a sole proprietorship called St. Clair                  
          Medical Center.3  Petitioner used the cash basis method of                  
          accounting to report his medical receipts on Schedule C of his              
          tax returns.  From October of 1985 through February of 1990,                
          Angela Paolella Alshabani (Ms. Alshabani) was petitioner's                  
               In 1988, Ms. Khana incorporated petitioner's medical                   
          practice under the name Superior Industrial Medical Center, Inc.            
          (Superior).4  Ms. Khana never received any money from Superior.             

               3  Petitioner used the names St. Clair Medical Center and              
          St. Clair Industrial Hospital (St. Clair IH) interchangeably.               
               4  During 1988, Superior conducted business under the name             
          of St. Clair Industrial Medical Center (St. Clair IMC).                     

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