New Orleans Louisiana Saints, Limited Partnership, Benson Football, Inc. Tax Matters Partner - Page 22

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          value that petitioner has allocated a portion of the acquisition            
          price.                                                                      
               Respondent agrees with neither of petitioner's contentions.            
          Instead, respondent argues that petitioner cannot allocate a                
          portion of the acquisition price to the Superdome leasehold                 
          because the Revised Lease was not an asset obtained from the                
          Mecom Group.  Respondent also contends that the allocation lacks            
          economic reality and was arbitrarily assigned for the purpose of            
          achieving favorable tax consequences.  Moreover, with respect to            
          petitioner's alternative argument, respondent maintains that the            
          1975 Lease was without substantial value and fails to qualify as            
          a premium lease.  We find petitioner's alternative argument                 
          persuasive.                                                                 
               Section 1012 sets forth the general rule that the basis of             
          property shall be the cost of such property.  Additionally,                 
          section 1060 sets forth special allocation rules for determining            
          a transferee's basis in certain asset acquisitions.  Section 1060           
          was added to the Internal Revenue Code in 1986, Tax Reform Act of           
          1986, Pub. L. 99-514, sec. 641(a), 100 Stat. 2085, 2282, and was            
          made effective for any acquisition of assets after May 6, 1986.             
          The parties have agreed to allocate the acquisition price in                
          accordance with the "residual method," as described in sec.                 
          1.1060-1T(d)(2), Temporary Income Tax Regs., 53 Fed. Reg. 27040             
          (July 18, 1988).                                                            






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