Michael T. Caracci and Cindy W. Caracci, et al. - Page 6




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          during all relevant times.  In the early years of their business,           
          Victor and Joyce Caracci borrowed money collateralized by their             
          residence to fund the Sta-Home tax-exempt entities’ operations,             
          and they (the individuals) guaranteed the extension of credit to            
          the entities.  Throughout the years, the managers of the three              
          separate entities generally operated the entities as one                    
          integrated unit.  (Because the parties also generally treat the             
          three separate entities as one integrated unit, so do we.)                  
          During the subject year, Joyce Caracci, Michael Caracci, and                
          Christina McQuillen were the Sta-Home tax-exempt entities’ only             
          directors and officers.  Those entities employed or retained the            
          following Caracci family members or spouses in the corresponding            
          position:                                                                   
          Individual                     Position                                     
          Victor Caracci        Consultant                                            
          Joyce Caracci         Chief operating officer/administrator                 
          Michael Caracci       Chief executive officer                               
          Christina McQuillen   Director of personnel                                 
          Vincent Caracci       General counsel                                       
          Denise Caracci        Nurse (from August 1991 to May 1995)                  
          David McQuillen       Maintenance man                                       
               The Sta-Home tax-exempt entities participated in the                   
          Medicare program.  Medicare was established in title XVIII of the           
          Social Security Act, Pub. L. 89-97, 79 Stat. 291 (1965), and is             
          the principal health care insurance for individuals who are                 










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