P.D.B. Sports, Ltd., Bowlen Sports, Inc., Tax Matters Partner - Page 6

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          at four NFL teams, to wit, Chicago Bears, Cleveland Browns, New             
          York Giants, and Houston Oilers.  These four individuals assigned           
          estimated values to the existing Bronco player contracts, which             
          when aggregated totaled $44,325,000, $43,450,000, $59,215,000,              
          and $35,790,000, respectively.  The average of these assigned or            
          estimated total values is $45,695,000.  Bowlen I's accountant               
          evaluated the assets of the partnership and the values assigned             
          to them by the partnership personnel.  The accountant analyzed              
          and adjusted the values of the partnership assets and determined            
          that the fair market value of the player contracts was                      
          $36,121,385 as of June 1, 1984, the date of the transfer of the             
          partnership interest to Bowlen.  The accountant's analysis was              
          conducted under the approach contained in the subchapter K                  
          partnership provisions where the appreciation in the value of the           
          assets over the partnership's presale basis in the assets is                
          allocated to the assets to account for the difference.  The                 
          difference between the partnership presale basis (approximately             
          $26 million) and Bowlen’s and Adams’ purchase price for the                 
          partnership interests including assumptions of liability                    
          (approximately $72 million) was about $46 million.5  The                    
          accountant's asset valuations and conclusions regarding the                 
          partnership's basis in the assets, including the player                     

               5 The $72 million basis reflects adjustments made by the               
          partnership that are not germane to this case to account for                
          Bowlen’s acquisition costs and Adams’ share of partnership income           
          prior to the sec. 708 termination.                                          




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