Sheldon R. and Phyllis Milenbach, et al. - Page 2

                                        -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:                                                                 









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