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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