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1056 applies to "the sale, exchange, or other disposition of a
sports franchise." The General Explanation is prepared by the
staff of the Joint Committee on Taxation and is generally not
considered to be legislative history. Courts, however, have
referenced the General Explanation in opinions involving the
interpretation of statutes. See, e.g., FPC v. Memphis Light,
Gas & Water Div., 411 U.S. 458, 471-472 (1973); Todd v.
Commissioner, 89 T.C. 912, 917-918 (1987), affd. 862 F.2d 540
(5th Cir. 1988). In any event, the General Explanation does not
contain elucidation or clear guidance on the application of
section 1056 to transfers of partnership interests, as respondent
argues. The General Explanation contains the amorphous phrase
"other disposition of a sports franchise" which we find
inconclusive on the question of whether partnership transactions
are covered by section 1056. To accept the "other disposition"
language as including the transfer of a partnership interest
would, of necessity, require us to ignore and/or circumvent
certain of the subchapter K special basis adjustments available
to a buying partner and other basis provisions governing
partnership transactions.
In that connection, the integration into subchapter K of a
basis limitation like that contained in section 1056 would be a
complex and arduous task. Subchapter K already contains a
complex and comprehensive set of basis provisions designed to
address the unique aspects of a pass-through entity. Such an
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