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Respondent, in the notice of deficiency for 1982 and in the
FPAA’s for 1983, 1984, 1985, and 1986, disallowed the Raiders’
rent deductions because the rent was not currently payable and
was considered part of the “loan” from the LAMCC. In the
alternative, if the rent deductions were allowed, respondent
determined that the amount advanced under the “loan” was
includable in gross income. For 1984, respondent determined that
the additional $4-million advance was includable in the Raiders’
gross income.
City of Oakland Lawsuit Settlement
The lawsuit filed by Oakland to keep the Raiders from moving
to Los Angeles was pending for several years and ultimately was
decided in favor of the Raiders. As part of that eminent domain
lawsuit, the Raiders filed a notice of claim for damages (notice
of claim) and a Supplemental Brief in Support of Right to Seek
Damages in the Present Action (supplemental brief). The notice
of claim sought damages for Oakland’s denial of the Raiders’
“free and untrammeled possession and use of the property sought
to be condemned and thereby preempted Raiders’ full possessory
right to the enjoyment and use of the Raiders’ property”. The
Raiders also claimed that Oakland had interfered with the
Raiders’ free use and enjoyment, thus taking property without
compensation. The notice of claim enumerated several ways, in a
nonexclusive list, in which Oakland had caused the Raiders to
suffer damages, including lost revenue and increased expense,
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