Horace D'Angelo - Page 4

                                         -4-                                          
          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           






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011