P.D.B. Sports, Ltd., Bowlen Sports, Inc., Tax Matters Partner - Page 2

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               Held, further:  Partnership correctly computed the basis in            
               the player contracts under the subch. K basis adjustment               
               sections and regulations thereunder.                                   


               Richard P. Slivka and Charles D. Henson, for petitioner.               
               Randall L. Preheim, for respondent.                                    


               GERBER, Judge:  Respondent issued notices of final                     
          partnership administrative adjustments to P.D.B. Sports, Ltd.,              
          for the taxable years 1989 and 1990.  Among other adjustments,              
          respondent disallowed amortization in the amounts of $1,878,056             
          and $259,255 for 1989 and 1990, respectively, claimed with                  
          respect to professional football player contracts.  After                   
          concessions, the sole issue remaining for our consideration is              
          whether the partnership, for purposes of determining the                    
          amortizable basis in player contracts, is subject to section                
          10561 in addition to, in conjunction with, or instead of the                
          subchapter K partnership provisions.  Petitioner contends that              
          the partnership provisions apply exclusively and would, in this             
          case, permit the amortization of the fair market value of the               
          player contracts.  Conversely, respondent contends that section             
          1056 applies to limit amortization to an amount equal to the                
          seller's basis, plus any gain recognized by the seller.  In                 

               1 All section and subchapter 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,            
          unless otherwise indicated.                                                 




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