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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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