Roger and Sharon Wortmann, et al. - Page 14

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          intervening 17 months before petitioners contributed the subject            
          property to a qualifying charitable organization.  These                    
          alterations included painting, maintaining the outside of the               
          structures, and completing the bathroom and sleeping areas.                 
          Neither TRY nor petitioners individually spent any time or money            
          on structural improvements or additions to the subject property.            
               Petitioners argue that the $75,000 purchase price is not               
          persuasive because it was a “forced sale”.  We disagree.                    
          Although Father Stevens testified that he wanted the property to            
          sell at a price to pay the debts plus a little seed money, there            
          is no evidence of any foreclosure activity or that any creditor             
          had begun any collection action.  In fact, although the Monks               
          Nonprofit was experiencing difficulty paying bills and needed to            
          liquidate its assets, the Monks Nonprofit was continuing to make            
          payments on the debt when due in the ordinary course of business.           
          Further, we are mindful that Father Stevens expressed that the              
          subject property must retain its religious purpose.  In fact,               
          Father Stevens testified that he would have preferred that the              
          Monks Nonprofit not have sold the subject property at all if                
          there was a risk the subject property would be used for                     
          nonreligious purposes.  In that case, Father Stevens testified              
          that he would have found another way for the Monks Nonprofit to             
          pay its liabilities.                                                        










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