Assets / Liabilities Notes Chapter 7

Assets

Estimated available cash - Household & Business 1 $ 1,176,956 

Old Bahama Bay Lot #51 (50% interest) 2 90,000 

Vehicles [1949 Ford Shoebox & 2020 GMC Yukon XL] 3 65,550 

Value of real estate held in operating entity 4 855,000 

Dallas ER, LLC 5 150,000 

Restaurant entities 6 1,239,146 

Chapter 5 and other causes of action 7 - 

Estimated assets available for distribution 3,576,652 

Liabilities

Secured Claims:

AmeriCredit/GM Financial [2020 GMC Yukon XL] 8 77,000 

 77,000 

Estimated assets available for distribution 3,499,652 

Administrative Claims:

Ch. 7 Administrative Expense Claims: 9

Chapter 7 Trustee Fees 131,000 

Chapter 7 Professionals 200,000 

 331,000 

Estimated assets available for distribution 3,168,652 

Estimated Chapter 11 Administrative Expense Claims:

Furr & Cohen (Counsel to Debtor) 10 150,000 

KapilaMukamal (FA to Debtor) 10 80,000 

IRS - post-petition tax liability 11 470,782 

 700,782 

Priority Claims:

Deanne Lee 12 3,000,000 

Department of Treasury 13 486 

 3,000,486 

Estimated assets available for distribution $ (532,616)

Total General Unsecured Claims ("GUCs") $ 4,490,304 

Estimated Distribution % to GUCs under Chapter 7 0.00%

Estimated Distribution % to GUCs under Chapter 11 14 11.14%

Total Guaranteed Entities Claims $ 1,683,125 

Estimated Distribution % to Guaranteed Entities under Chapter 7 0.00%

Estimated Distribution % to Guaranteed Entities under Chapter 11 15 15.00%

Source: Bankruptcy schedules, claims filed, pleadings and the Debtor's financial records. 

Petition Date: October 23, 2020

Assumed Chapter 11 Effective Date: January 1, 2022

SEE ACCOMPANYING NOTES

ALEXANDER DONG LEE

CASE NO. 20-21594-BKC-SMG UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA - FORT LAUDERDALE DIVISION

Liquidation Analysis

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Case 20-21594-SMG Doc 277-3 Filed 01/07/22 Page 1 of 2
Source: Bankruptcy schedules, claims filed, pleadings and the Debtor's financial records. 

Petition Date: October 23, 2020

Assumed Chapter 11 Effective Date: January 1, 2022

ALEXANDER DONG LEE

CASE NO. 20-21594-BKC-SMG UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA - FORT LAUDERDALE DIVISION

Liquidation Analysis

Notes:

15) In accordance with the plan, the Guaranteed Entities will receive an additional $250,000, distributed pro

rata on the Effective Date.

13) Priority claims per the bankruptcy schedules or proof of claim forms.

14) In accordance with the plan, the holders of Allowed General Unsecured Claims will receive $500,000, 

distributed pro rata on the Effective Date. Holders of Allowed General Unsecured Claims will receive no 

further distribution. 

4) The FMV of the real estate held by the operating entities (in which the Debtor holds an interest) is 

approximately $2.6 million less the associated debt of approximately $1.65 million and 10% for commission 

and closing costs. 

3) Estimated value of the Yukon based on the Kelly Blue Book Value and Debtor's estimate of the Ford 

Shoebox less 5% for the costs to sell the vehicles. 

10) Compensation to the Debtor's bankruptcy professionals is subject to Court approval. 

1) Estimated available cash as of November 30, 2021 monthly operating report filed with the Court. This 

amounts does not include funds held in Debtor's counsel Trust account that are exempt Homestead 

proceeds.

8) Secured claims per the bankruptcy schedules or proof of claim forms.

9) The Chapter 7 Trustee fees were estimated pursuant to the Bankruptcy Code if allowed in full and the 

professional fees to administer the Chapter 7 estate are estimated and are subject to Court approval.

2) The amount listed is the 50% of the value of land listed in the bankruptcy schedules less an estimated 

10% for commission and closing costs to sell the property. 

6) The estimated value of the Debtor's interest in the restaurants was based on EBITDA for the rolling 12-

month period July 1, 2020 through June 30, 2021 and using a valuation multiple of three (3) that was 

derived from Dunn & Bradsheet First Research Industry Profile, October 25, 2021 NAICS Codes 722511 

(pg. 15: Median Value for MVIC/EBITDA), less 10% for closing costs and a broker's commission fee. 

5) The estimated liquidation value of the Debtor's interest in Dallas ER, LLC . The Debtor can only transfer 

his interest to another EM boarded physician licensed in Texas with unanimous approval of the remaining 

11 partners. The amount is based on the Debtor's original investment amount.

7) KapilaMukamal assumed there were no Chapter 5 causes of action based on a review of the Debtor's 

bank records.

12) Estimated claim amount for the Debtor's spouse based on the July 2021 settlement agreement (POC 

23). 

11) Estimated post-petition tax liability due and based on approximately 40% of the cash balance as of 

September 30, 2021. The Debtor's post-petition tax return has not been finalized and the actual amount 

due may be more or less than the Debtor estimated. Additionally, the estimated tax liability may be 

mitigated by NOLs available to the Debtor the value if which is undetermined at present.

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