Likely the same situation where the big CPA firm up north screwed up and nearly cost my client tens of thousands in taxes until they came to me for help and I found the relevant PLR.  Your client might have purchased goodwill many years ago, and amortized it.  If that goodwill still had value, at least some of the amortization has to be recaptured.  But if those patients and their friends are long since gone, the goodwill sold was not what was amortized, and you don't have a recapture problem.  Lots of facts and circumstances to be sorted out in a day.