- 38 -
Average Rates of Return
FY90 FY91 FY92 FY93 FY90-FY93
Petitioner 6.3% 24.9% 34.9% 43.5% 27.4%
SCA Centers 4.4% 17.3% 25.4% 31.5% 19.6%
Limited Partners 5.1% 21.4% 31.0% 38.5% 24.0%
Upon its Form 1023, Application for Recognition of
Exemption, under section 501(c)(3), filed August 7, 1990,
petitioner estimated that between 50 and 80 percent of its total
annual income would be used to support RHS and Redlands Hospital,
which were stated to have total annual losses of $340,544 and
$460,595, respectively. Petitioner has used its share of the
cash distributions from the Operating Partnership to pay off the
note payable to SCA for its initial capital contribution9 and to
make distributions to RHS or Redlands Hospital.
Final Adverse Ruling
In its final adverse ruling, respondent determined that
petitioner is "not operated exclusively for charitable purposes
within the meaning of section 501(c)(3). You are operating for a
substantial nonexempt purpose and your operations benefit private
interests more than incidentally."
9 The note payable to SCA of $769,829 was paid in full by
April 1992.
Page: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 NextLast modified: May 25, 2011