-2--2- P’s were partners of the Raiders, a professional football team that received municipal funds repayable only from specific sources of revenue. The partnership also received funds from settlement of a lawsuit brought by the City of Oakland. 1. Held: Amounts received from the Los Angeles Memorial Coliseum Commission as “loans”, to be repaid from revenue received from luxury suites, are taxable when received, because the obligation to repay was not unconditional. 2. Held, further, damages received from the City of Oakland were not allocated to goodwill or franchise value and are thus taxable. 3. Held, further, income from discharge of indebtedness resulted when the agreement to build a stadium in the City of Irwindale became unenforceable. Bad debt issue also resolved. Barrie Engel, for petitioners. David W. Sorensen and Paul L. Dixon, for respondent. COHEN, Judge: Respondent determined deficiencies in Sheldon R. and Phyllis Milenbach’s Federal income taxes as follows: Docket No. 28514-92 Year Deficiency 1980 $2,749 1981 1,822 1982 4,499 Respondent issued notices of Final Partnership Administrative Adjustments (FPAA’s) determining adjustments to partnership items as follows:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011