-14-
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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