Anclote Psychiatric Center, Inc. - Page 40

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            1985 and 1986 because the major portion of its expenditures                                  
            during those years, namely, payments to FPCF and to AMH for                                  
            patient care, constituted prohibited inurement to the board                                  
            members.  Petitioner also treats respondent's argument as an                                 
            alternative and does not ask us to grant it exempt status during                             
            the aforesaid years if we conclude, as we do, that it lost such                              
            status at an earlier date.  In this connection, petitioner points                            
            out that this issue is subsumed in the issues involved in docket                             
            No. 27403-92X wherein petitioner filed a petition, in response to                            
            respondent's action in respect of its request for exempt status                              
            after October 1, 1983, seeking a declaratory judgment that it was                            
            exempt in the years after the sale.                                                          
                  We now turn to the question of whether petitioner, as a                                
            taxable entity during the years at issue herein, is entitled to                              
            certain deductions in computing its taxable income.  These                                   
            deductions are for amounts due FPCF, for grants to organizations                             
            and patient care and for a claimed net operating loss                                        
            carryforward from its 1983 fiscal year.                                                      
            FPCF                                                                                         
                  Petitioner had contingent liabilities to the FPCF at various                           
            times during its fiscal year 1983 and subsequent taxable years                               
            with respect to its hospital activities prior to the May 1983                                
            sale.  The deductibility of those liabilities to the extent that                             
            they became fixed or paid during the years is at issue herein.                               





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