Tampa Bay Devil Rays, Ltd., Naimoli Baseball Enterprises, Inc., Tax Matters Partner - Page 16




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               Artnell Co. v. Commissioner, 400 F.2d 981 (7th Cir. 1968),             
          acq. 1968-2 C.B. 1, revg. and remanding 48 T.C. 411 (1967),                 
          involved facts very similar to those involved herein.  Therein              
          the Court of Appeals for the Seventh Circuit concluded that funds           
          received by the Chicago White Sox, Inc. (White Sox) on advance              
          ticket sales relating to major league baseball games to be played           
          in a following year may appropriately be deferred and included in           
          the White Sox’s income in the year when the games were to be                
          played if that deferral would clearly reflect the White Sox’s               
          income.  Id. at 985.  The Court of Appeals for the Seventh                  
          Circuit remanded the case to us for analysis of whether the White           
          Sox’s deferral of reporting the funds as income until the year in           
          which the games were played would clearly reflect income.  Id. at           
          985-986.                                                                    
               On remand in Artnell Co. v. Commissioner, T.C. Memo. 1970-             
          85, we concluded that the White Sox’s method of accounting for              
          the funds clearly reflected income because deferral of the funds            
          until the year in which the games were played more clearly than             
          respondent’s method matched the income with the White Sox’s major           
          expenses that were incurred in the year when the games were                 
          played.                                                                     
               In subsequent opinions, we have stated that Artnell Co. will           
          be limited to its facts.  See Johnson v. Commissioner, 108 T.C.             
          448, 492 (1997), affd. in part, revd. in part, and remanded on              






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