It is unclear when HUD began its policy of allocating a portion of the net operating income and of the going-concern value
to proprietary earnings, but James K.
Baird and Rasmussen's premise that going-concern value
If we assume that assets can be sold for their estimated going-concern value
, a typical firm's return matches the return to a benchmark portfolio.
TEI submits that there is no statutory basis for denying like-kind treatment for goodwill or going-concern value
1 of The Appraisal of Real Estate, 13th edition (Appraisal Institute, 2008, page 30), where the going-concern value
of a business enterprise is divided between tangible property (composed of personal property and real property) and intangible property of various types.
1031(a)-2(c)(2), a business's goodwill and going-concern value
are not like-kind to the goodwill and the going-concern value
of another business.
In fact, even the going-concern value
of an agency (tangible assets plus intangible assets, such as goodwill) may have little bearing on the actual purchase price of an agency.
the remaining cases, going-concern value
was small or nonexistent.
We define our estimates as the difference between the going-concern value
and the liquidation value of the firm's assets.
Although Golf Trust has not yet acquired ownership of the Innisbrook Resort, as previously disclosed, Golf Trust has based its calculation of the mortgage's liquidation value on an estimate of the future going-concern value
of the Resort's operations on the assumption that Golf Trust will take possession of the Resort (subject to an amended management contract with Westin) and hold the property until operating revenues realize a modest recovery.
Immediately before the effective date of the election, the fair market value (FMV) of FS's assets, including intangible assets such as goodwill and going-concern value
, was less than the sum of its liabilities.
The going-concern value
of any hospitality property is as much influenced by competitive position in terms of its business as it is by real estate parameters.