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We do not believe that this is such an unusual case. The
dormant state of the Sta-Home tax-exempt entities precludes
calling into question whether, on the whole, they are functioning
tax-exempt entities. Moreover, we perceive three reasons why it
is not appropriate to remove their tax-exempt status at this
time. First, the excess benefit represented the fair market
value of the Sta-Home tax-exempt entities’ assets less the
liabilities assumed by the Sta-Home for-profit entities. Given
that we have already sustained the imposition of intermediate
sanctions as to this excess value, we do not believe it
appropriate under the facts herein to conclude that the single
transaction (as to each entity) underlying the excess value also
requires our revocation of each entity’s tax-exempt status.
Second, the Sta-Home tax-exempt entities have not since the
transfers been operated contrary to their tax-exempt purpose.
Third, we find some credence in petitioners’ suggestion that
maintenance of the tax exemption may enable them to utilize the
correction provisions made available in sections 4961 through
4963. While the issue is not ripe for us to decide at this time,
we note that a permissible correction may require that the
Sta-Home for-profit entities transfer the assets back to the
Sta-Home tax-exempt entities. If we were to remove the Sta-Home
tax-exempt entities’ tax-exempt status at this stage, however,
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