-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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