Anclote Psychiatric Center, Inc. - Page 28

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            in their negotiations which culminated in the 1983 sale.                                     
            Additionally, when analyzing petitioner's revenues and expenses                              
            for purposes of the income approach to valuation set forth in his                            
            appraisal, Mr. Shelton states:                                                               
                  Prior to the sale, and at the time when the hospital                                   
                  was owned by a not-for-profit organization, maximizing                                 
                  patient revenues per patient day and net income were                                   
                  not priority matters as they were consumed with their                                  
                  "totally in-secret plans" to purchase the hospital.                                    
                  However, the Board did not want to do anything to make                                 
                  the contemplated sale suspect as the members of the                                    
                  board covertly made preparations to sell the hospital                                  
                  to themselves.  Thus expenses in the years immediately                                 
                  prior to and in the year of sale were higher than                                      
                  normal because of fees and costs related to the                                        
                  preparation and the related sale expenses.                                             
            Finally, in his overall conclusion, Mr. Shelton states that the                              
            Board of Directors of petitioner "covertly schemed and planned                               
            the successful purchase of the hospital to their inurement and at                            
            the expense of this 501(c)(3) corporation".                                                  
                  We think that Mr. Shelton's report is more characteristic of                           
            the work of a revenue agent than of an impartial, disinterested                              
            appraiser.  In this connection, we note that Mr. Shelton's report                            
            was received and adjusted by respondent's National Office.  We                               
            reject respondent's suggestion that we exclude Mr. Shelton's                                 
            objectionable comments and admit the balance of his report.                                  
            Those comments impart a pervasive negative impact on the report.                             
            We conclude that petitioner's objection based on bias is well                                








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