Tampa Bay Devil Rays, Ltd., Naimoli Baseball Enterprises, Inc., Tax Matters Partner - Page 11




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               On March 31, 1998, the Devil Rays played its first major               
          league baseball game against the Detroit Tigers and lost the game           
          11 to 6.  The Devil Rays apparently played all its scheduled                
          major league baseball games for 1998 on their scheduled dates.              
               In 1998, the partnership began incurring significant                   
          additional expenses (that it had not incurred in prior years)               
          relating to its first season in major league baseball.                      
          Substantially all the additional expenses relating directly to              
          the major league baseball games the Devil Rays played in 1998               
          were incurred in 1998 (e.g., player salaries, stadium rental, and           
          game-day operations).                                                       
               For financial and tax purposes, the partnership maintains              
          its books and records on the accrual method of accounting.                  
               On its financial books and records for 1995 and 1996, taking           
          into account yearend adjusting entries, the partnership treated             
          the deposits it received in 1995 and in 1996 on advance season              
          tickets and on private suite reservations as deferred revenue               
          (i.e., as liabilities, not as income).                                      
               On its Federal partnership tax returns for 1995 and 1996,              
          the partnership treated expenses relating to its minor league               
          baseball activities and to general operating and overhead costs             
          as current business expense deductions.4                                    




          4    The partnership did deduct on its 1995 and 1996 partnership            
          tax returns the current year annual interest expense relating to            
          the loan obtained to pay the $130 million franchise fee.                    



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