Anclote Psychiatric Center, Inc. - Page 46

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            on their fair market value and then the gain or loss on the                                  
            individual assets determined.  Other than the assets of cash and                             
            Treasury bills, the record before us contains little information                             
            with which to ascertain the fair market value of the individual                              
            assets.  In this connection, we note that any such allocation                                
            would require us to determine specific fair market values in                                 
            contrast to the range standard which we were able to apply in                                
            respect of the inurement issue.                                                              
                  Petitioner's allocation of the purchase price has several                              
            defects, one of which is that it is based upon book values of                                
            assets rather than fair market values.  In any event, we have                                
            increased the purchase price, and therefore decreased                                        
            petitioner's loss by $300,000 representing obligations to                                    
            petitioner's pension plans assumed by AMH.  We have also                                     
            determined that the FPCF expenses are not deductible in the post-                            
            1983 years, and the same reasoning applies to the $354,580                                   
            reported as an FPCF item on the Form 990 for fiscal 1983.  These                             
            two adjustments total $654,880 and reduce petitioner's claimed                               
            loss to $51,942.  We are satisfied that a sufficient portion of                              
            the loss on the sale of the hospital would be capital so as to                               
            eliminate any remaining loss, if there was a loss at all.                                    
            Regardless, petitioner has not met its burden of proving, see                                
            supra p. 21, that it had a net operating loss for 1983.                                      







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