- 2 - Income Year Adjustments 1995 $3,328,455 1996 3,689,182 Unless otherwise indicated all section references are to the Internal Revenue Code for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The primary issue for decision is whether deposits the partnership received in 1995 and 1996 on advance season tickets and on private suite reservations for major league baseball games expected to be played in 1998 are to be included in the income of the partnership when received in 1995 and 1996, or in 1998, the year to which the advance season tickets and the private suite reservations related and the first year in which the partnership’s major league baseball team (the Devil Rays) played major league baseball. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The partnership was formed as a limited partnership on August 10, 1994, under the laws of the State of Florida. At the time the petition was filed, the partnership’s principal place of business was located in St. Petersburg, Florida. The partnership was formed to acquire, own, manage, and operate a major league baseball team in St. Petersburg, Florida.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011