- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011