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for much of the substantial value of the Sta-Home tax-exempt
entities’ intangible assets. Hahn ascertained a value for two
intangible assets. He first developed a value for the Sta-Home
tax-exempt entities’ workforce in place of $2.1 million to $3.4
million. He used the $2.1 million value in both the “base case”
and “best case” scenarios. He fails to justify using the lower
value in the “best case” scenario. Petitioners have assembled a
workforce of approximately 1,000. A very substantial proportion
of them are highly trained professionals, including registered
nurses and other trained medical personnel. The Sta-Home tax-
exempt entities employed 25 percent of the full-time and 17
percent of the part-time home health care staff in the State of
Mississippi. If Hahn has developed an approximate value of $3.4
million, we see no reason not to employ this estimate in the
“best case” scenario. Indeed, we suspect that the value of the
workforce is higher, but on this record, we cannot reasonably
estimate how much.
With respect to another intangible asset, Hahn’s “best case”
scenario ascribed a value of $667,000 to the “cost gap” attribute
that the Sta-Home tax-exempt entities presented for a qualifying
buyer. His valuation is based on the assumption that the value
of this attribute would end after 1 year. This value is too low.
The cost gaps were available under the then-current reimbursement
program. They would cease to exist under a PPS. Although there
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