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<br /> - Ity <br /> XI. ALTERNATIVES TO THE DEBTOR'S PLAN <br /> While there are several alternatives to the Plan, the Plan Proponent does <br />not believe that any of these alternatives represent a more desirable option <br />for Creditors. One alternative is a liquidation of the Debtor. The Debtor <br />could attempt to sell its business as a going concern and pay the proceeds to <br />its Creditors. In light of HealthVest's Secured Claim, the large Priority Tax <br />Claim of the IRS, as well as the costs of sale and other Administrative <br />Expense Claims, it is unlikely that a sale of the business as a going concern <br />would result in a 100'<: distribution on Unsecured Claims. A significant --~ <br />portion of the value of Debtor's operations is tied to its being part of the <br />Brown Schools system. If the Brown Schools system is broken up, as it would <br />probably be in a liquidation, much of that value would be lost. <br /> Alternatively, the Debtor's Chapter 11 case could be converted to a <br />Chapter 7 case. In a Chapter 7 liquidation, the expenses of the Chapter 7 <br />trustee and any professionals employed by this Chapter 7 trustee take priority <br />over payment of unsecured creditors. Because a Chapter 7 liquidation would <br />involve the termination of the Debtor's business, profits from operations <br />would cease within a short while, even if the trustee continued to operate the <br />business on a limited basis. Much of the going concern value of the DeQtor <br />would be lost in such a liquidation. HealthVest would probably foreclose its <br />mortgage on Debtor's treatment center and Debtor would not have a going <br />concern to liquidate. In the event of such a liquidation, it is extremely <br />unlikely that Unsecured Credi tors would be paid in full and those Creditors <br />who presently do business with the Debtor would lose the b~nefit of all future <br />business. <br /> A third alternative would be a different plan of reorganization. The <br />Plan Proponents are not aware of an alternative plan that would provide a <br />greater benefit to the creditors than the Plan. As discussed in Section X(B), <br />no alternative plan can pay Unsecured Claims in full on the Effective Date <br />because of the terms of the compromise of the IRS. <br /> XII. FEASIBILITY OF THE PLAN <br />A. Fundinq of Installment Payments I <br /> Based on Debtor's historical performance and the projections attached <br />hereto as Exhibit "Cu, Debtor will be able to pay all current operating <br />expenses, including cent, and have sufficient operating income to make all <br />installment payments required by the Plan. <br /> - 24 - <br />a-ZQISS <br />