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Neuro Care Limited Partnership (Lakeland), and Crittenton
Development Center (Crittenton).
Arbor was an S corporation that handled the day-to-day
record-keeping and management of the entities owned in whole or
in part by petitioner and Pomeroy. Its stock was owned equally
by petitioner and Pomeroy until 1996 when Pomeroy transferred all
of his stock in Arbor to petitioner in connection with the
lawsuits discussed infra. Arbor employed and paid the management
staff for the nursing homes that it managed. These management
fees were then charged to the nursing home to the benefit of
which the services in question inured. Petitioner was Arbor’s
president and managed its daily affairs.
H.K. Peach was an S corporation owned equally by petitioner
and Pomeroy. PNC was a partnership formed for the purpose of
leasing certain land and nursing homes constructed thereon. PNC,
an accrual basis taxpayer, was owned equally by H.K. Peach and
Crittenton. REH1 was an S corporation which owned and operated
the industrial real estate properties. REH1 was owned 25 percent
by petitioner, 25 percent by Pomeroy, and 50 percent by other
unrelated individuals. TROY-SAK was a real estate partnership
owned 25 percent by petitioner and 75 percent by Pomeroy and two
other individuals whose names are not material to this case.
Lakeland was a partnership owned 90 percent by REH1 and 10
percent by an unrelated entity named CMS Lakeland, Inc. Lakeland
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Last modified: May 25, 2011