In Cal-American Income Property Fund VII v. Brown Development Corp. (1982) 138 Cal.App.3d 268, the plaintiff argued the trial court had appointed a "'rents and profits'" receiver, and that the receiver's powers were expressly limited to the express terms of the appointment order. Therefore, the plaintiff argued that the trial court had erred in confirming the sale of the subject property. (Id. at p. 273.) The appellate court concluded that although the original stipulation requesting appointment of a receiver did not expressly refer to the receiver's authority to sell property, it did not preclude the possibility of a sale. (Id. at p. 274.) Additionally, the trial court's order appointing the receiver granted the receiver broad authority to do "such acts respecting the property as the court may authorize." (Ibid.) The court had also retained jurisdiction to allow any of the parties to apply for further orders or modifications of existing orders. Upon review, the Cal-American court determined the trial court had correctly concluded the receiver had the power to sell the property subject to confirmation, but decided the receiver had failed to present sufficient facts warranting exercise of the power to sell. (Id. at pp. 274, 276-277.) The court held that, to justify the sale of property, a receiver must "establish actual . . . necessity for the sale citation and also . . . demonstrate the sale has to be consummated at that time." (Id. at p. 275.) To satisfy this burden, the receiver must provide evidence showing "both that the property will be lost to creditors at some future time unless the court orders the sale and that the sale has to occur within a specified time to avoid such a loss." (Ibid.) "Evidence the property is faced with . . . substantial devaluation could justify an immediate sale to any available purchaser." (Id. at p. 275, fn. 7.)