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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
secretary.
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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