P.D.B. Sports, Ltd., Bowlen Sports, Inc., Tax Matters Partner - Page 11

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          partnership's player contracts is limited to the presale basis in           
          the contracts.                                                              
               Respondent argues that section 1056 would limit the                    
          amortizable basis of the partnership's player contracts in this             
          case.  Respondent, however, does not discuss or explain how or if           
          the section 1056 limitation would otherwise affect partnership              
          provisions, including sections 732(d), 743(b) and/or 754 which              
          may have been considered or have been in play in the transaction            
          under consideration.  Respondent does not explain whether section           
          1056 would preempt the application of other basis requirements              
          and/or elections under subchapter K or whether it would be                  
          integrated in some manner.  These unanswered questions are                  
          problematic and complicate our proper analysis of respondent's              
          determination.  Additionally, no regulations have been issued               
          under section 1056, although, in the 1976 legislation, respondent           
          was statutorily mandated to issue regulations.                              
               In the alternative, if we decide that the partnership                  
          provisions of subchapter K apply to the exclusion of section                
          1056, respondent argues that the partnership incorrectly computed           
          its basis in the player contracts, and, as a result, no player              
          contract bases remain to be amortized.                                      
          II.  Section 1056--Does It Apply to Partnership Transactions?               
               Section 1056 applies to a "sale or exchange" of a sports               
          franchise.  In this case, the sports franchise was held in                  
          partnership form so that any sale or exchange of a sports                   




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