- 17 - the noncompete agreements. Petitioners were determined to avoid that possibility. At some point in the negotiations, petitioners and the other UHMG physicians decided to pursue exclusively an affiliation with Sutter Health. Thereafter they retained an attorney, Peter Grant, to advise them with respect to the transaction with SMF. Mr. Grant, whose fees were paid by SMF, was experienced in matters affecting health care organizations, including acquisitions of physician practices. Mr. Grant recommended that, in light of Sutter Health's unwillingness to pay cash for goodwill or similar intangible assets associated with the physicians' practices, petitioners should consider donating their practice intangibles to SMF and claiming charitable contribution deductions for their values. Mr. Grant recommended that petitioners structure the transfers of the intangibles as donations because that technique had been used in connection with an acquisition of a group medical practice by a nonprofit medical foundation (Friendly Hills Healthcare Foundation), for which Mr. Grant had served as an adviser. Mr. Grant had received a written determination in the form of a determination letter granting section 501(c)(3) tax-exempt status to Friendly Hills Healthcare Foundation, where it had been represented that the medical group physicians would make donations of an aggregate portion of the transferred assetsPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 NextLast modified: March 27, 2008