- 7 - 1. An independent appraisal by a qualified competent appraiser will be obtained, which determination will be the basis of the price and terms upon which the hospital will be sold. 2. All documents necessary for the closing of the proposed sale and related consents will be negotiated and prepared by separate counsel for APC and the purchasing entity. * * * * * * * Following Mr. O'Donnell's recommendation, the board hired Ray J. Sheldrick (Mr. Sheldrick), a business appraiser, to determine the fair market value of the hospital. On March 5, 1982, Mr. Sheldrick submitted to petitioner his Summary Valuation Report, effective as of September 30, 1981. Using the asset- based approach, Mr. Sheldrick determined the fair market value for the hospital as of September 30, 1981, to be in the range between $3,500,000 and $4,300,000. Mr. Sheldrick's appraisal did not include the Belcher Road property or County Road #77 property. On May 27, 1982, the IRS issued a PLR to petitioner. After reiterating the facts as submitted by petitioner and presenting the applicable law, the PLR states: As noted, arms-length standards will prevail during the negotiations and sale, as you will certify by maintaining appropriate records, attesting to the fact that the price was set at fair market value and that no loan abatements or other special concessions will be afforded to the present directors in their capacity as purchasers and/or operators of thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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