Tampa Bay Devil Rays, Ltd., Naimoli Baseball Enterprises, Inc., Tax Matters Partner - Page 2




                                        - 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.            







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Last modified: May 25, 2011