P.D.B. Sports, Ltd., Bowlen Sports, Inc., Tax Matters Partner - Page 3

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          particular, the controversy centers on whether section 1056 was             
          intended to apply where the buyer acquires a partnership interest           
          in a partnership holding player contracts.                                  
                                  FINDINGS OF FACT2                                   
               Patrick Bowlen (Bowlen), after graduating from the                     
          University of Oklahoma law school, practiced law for 2 years in             
          Calgary, Canada.  Thereafter, he began a real estate development            
          business which he operated into the late 1980's.  During 1984-85,           
          Bowlen acquired an interest as a general partner in a partnership           
          that was the franchised owner and operator of the Denver Broncos            
          (Broncos) professional football team, a member of the National              
          Football League (NFL).  That partnership, P.D.B. Sports, Ltd.               
          (Bowlen I), was a Colorado limited partnership with its principal           
          place of business in Colorado at the time the petition was filed.           
               Prior to Bowlen's involvement in the Broncos, Bowlen I was             
          99.75-percent owned by Edgar F. Kaiser, Jr. (Kaiser), a Canadian            
          national.3  The remaining .25 percent of Bowlen I was also                  
          indirectly owned by Kaiser, through a corporation E.F.K. Sports             
          Holdings, Ltd. (Kaiser I).  Due to Bowlen's prior interest in               



               2 The parties' stipulation of facts and the attached                   
          exhibits are incorporated herein by this reference.                         
               3 Bowlen I, prior to the transactions in question and when             
          controlled by Kaiser, had been named E.F.K. Sports, Ltd.  When              
          Bowlen acquired a partnership interest, he changed the                      
          partnership name from E.F.K. Sports to P.D.B. Sports, Ltd.                  
          (referred to as Bowlen I for purposes of this opinion).                     




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