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these positions. The Chamberlin Corp. purchased the inventory,
intangible property, personal property, and equipment of
Pharmacare from the trustee in bankruptcy for $200,000 and then
immediately transferred ownership to petitioner. On
September 18, 1981, in a three-party agreement, petitioner
purchased the Largo facility from the Pharmacare trustee in
bankruptcy by giving The Chamberlin Corp. a $183,800 promissory
note and assuming $572,046 of debt secured by the property. The
Chamberlin Corp. then paid $177,954 of Pharmacare debt on behalf
of the trustee and $4,077 of transfer expenses. Petitioner
rented the Largo facility back to The Chamberlin Corp. from 1981
until 1984.
On November 3, 1982, petitioner obtained a personal loan
from the Freedom Federal Savings & Loan Association (Freedom
Federal) in the amount of $1,750,000. This loan was secured by a
first mortgage on the principal residence of petitioners in
Greenwich, Connecticut. Four hundred fifty thousand dollars of
the loan proceeds was then reloaned by petitioner to The
Chamberlin Corp. and used to pay off debts of The Chamberlin
Corp. The Chamberlin Corp. also obtained loans from the
Ingersoll-Rand Financial Corporation (Ingersoll-Rand) in the
amount of $1,800,000, personally guaranteed by petitioner, and
loans in the amounts of $750,000 and $250,000, secured by second
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