-3--3-
Docket Adjustments Other
Number Year Ended to Ordinary Income Adjustments1
1573-93 12/31/83 $ 1,239,528 $ 57,386
1574-93 12/31/84 4,990,534 35,505
1571-93 12/31/85 787,108 60,442
1572-93 12/31/86 1,149,513 121,759
12129-94 12/31/87 10,029,373 100,871
12129-94 12/31/88 11,616,054 51,973
12129-94 12/31/89 11,064,920 (300)
1The “Other Adjustments” related to respondent’s determination of
adjustments in the allowable depreciation and amortization deductions in each
year.
After concessions by the parties in two stipulations of
settled issues and a concession on brief by petitioners, the
issues remaining for decision are: (1) Whether $6.7 million
received from the Los Angeles Memorial Coliseum Commission during
the period 1982 through 1986 constituted taxable income to the
Los Angeles Raiders; (2) whether settlement payments received
during 1988 and 1989 from the City of Oakland constituted taxable
income to the Los Angeles Raiders; (3) whether $10 million
received from the City of Irwindale constituted taxable income to
the Los Angeles Raiders in 1987, 1988, or 1989; and (4) whether
the Los Angeles Raiders were entitled to a bad debt deduction in
1986.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. The use of the term “loan” in the Findings of Fact is
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