Sheldon R. and Phyllis Milenbach, et al. - Page 4

                                        -4--4-                                          
          for convenience and is not conclusive as to characterization for            
          tax purposes.                                                               
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
               Sheldon R. and Phyllis Milenbach resided in Oakland,                   
          California, at the time their petition was filed.  Sheldon R.               
          Milenbach was a limited partner of the Los Angeles Raiders (the             
          Raiders) during 1980 through 1982.  Allen Davis is the tax                  
          matters partner for 1983 through 1986.  A.D. Football, Inc., is             
          the tax matters partner for 1987, 1988, and 1989.                           
               The Raiders own and operate a professional football club and           
          hold a franchise in and are a member of the National Football               
          League (NFL).  During the years in issue, the Raiders' principal            
          places of business were Oakland, California, and Los Angeles,               
          California, respectively.  For many years prior to 1980, the                
          Raiders played their professional football games at the Oakland-            
          Alameda County Coliseum (Oakland Coliseum) in Oakland,                      
          California.  The Raiders’ lease of the Oakland Coliseum expired             
          at the close of the 1979 NFL season.                                        
          Los Angeles Coliseum Agreement                                              
               During 1979, the Raiders undertook negotiations with the               
          management of the Oakland Coliseum to amend and extend the term             
          of the then-about-to-expire lease.  The Raiders were also                   
          negotiating with the Los Angeles Memorial Coliseum Commission               




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