Anclote Psychiatric Center, Inc. - Page 5

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            paid for their treatment and those who paid themselves.  However,                            
            petitioner never admitted Medicare or Medicaid patients.                                     
                  The hospital is situated on about 20 acres.  In addition,                              
            petitioner owned two nonadjacent unimproved parcels known as the                             
            Belcher Road property (approximately 4.2 acres) and the County                               
            Road #77 property (approximately 76 acres) and two waterfront                                
            lots across the street from the hospital.  Blanton Realty                                    
            appraised the Belcher Road property for $210,000 as of March 5,                              
            1981.  As of July 8, 1982, Blanton Realty appraised the County                               
            Road #77 property at $836,000 and the two lots at $60,000.                                   
            The Sale of the Hospital                                                                     
                  In or about 1980, Dr. Wellborn and a few board members                                 
            attended several meetings of the National Association of Private                             
            Psychiatric Hospitals where information was given about                                      
            restructuring psychiatric hospitals; hospitals were changing from                            
            not-for-profit to for-profit organizations.  Dr. Wellborn and the                            
            other board members were looking for ways to generate funds to                               
            expand the hospital and, at the same time, support petitioner's                              
            research and educational goals.  Dr. Wellborn wished to continue                             
            running the hospital, and the board supported that relationship.                             
                  Sometime in the first half of 1981, the board engaged James                            
            O'Donnell (Mr. O'Donnell), a Jacksonville, Florida, tax attorney,                            
            to advise them regarding converting to a for-profit entity, with                             
            the possible sale of the hospital to an entity to be formed by                               





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