-18--18-
the agreement for the 1986 season were not due, however, until
the spring of 1987.
Jeffrey Birren (Birren), in-house counsel for the Raiders,
was involved in attempting to collect from Speck during 1986.
Birren met face to face with Speck several times during 1986 to
discuss collection. Speck, in a letter dated November 20, 1987,
disputed the amount of the remaining balance owed for the 1985
season, but Speck agreed that some amount was still owed on the
1985 contract and that approximately $200,000 was still owed on
the 1986 contract. In a letter dated December 7, 1987, the
Raiders indicated that they were still seeking collection of the
remaining balance that Speck owed from the 1985 and 1986 seasons.
The Raiders and Speck continued to do business until sometime
after 1990.
The Raiders deducted $400,000 ($200,000 due from Speck for
the 1985 agreement and $200,000 of the $750,000 due from Speck
for the 1986 agreement) as a bad debt deduction on their 1986
Federal income tax return. Respondent, in the FPAA for 1986,
disallowed the deduction because the Raiders had not established
that the debt had become worthless during 1986.
OPINION
Los Angeles Coliseum Agreement
Gross income, as used in the Internal Revenue Code, includes
all income from whatever source derived, sec. 61(a), encompassing
all “accessions to wealth, clearly realized, and over which the
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