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On its Federal partnership tax returns for 1995 and 1996,
the partnership did not deduct as accrued expenses any of the
anticipated expenses relating directly to the major league
baseball games to be played by the Devil Rays in 1998 (e.g.,
major league baseball player salaries, stadium rental, and game-
day operations).
Further, on its 1995 and 1996 Federal partnership tax
returns, the partnership did not accrue business expense
deductions of $27,753 and $8,500 incurred in 1995 and 1996,
respectively, relating to the marketing and sale in 1995 and 1996
of advance season tickets and private suite reservations.
Rather, those expenses were deferred and deducted on the
partnership’s 1998 Federal partnership tax return for 1998, the
year in which the games were played.
On its Federal partnership tax returns for 1995 and 1996,
the partnership did not include in income the deposits the
partnership received during 1995 and 1996 (on the advance season
tickets and on the private suite reservations relating to the
anticipated 1998 major league baseball season). Rather, the
deposits received in 1995 and 1996 on the advance season tickets
and on the private suite reservations were reported by the
partnership as income on the partnership’s Federal partnership
tax return for 1998, the year in which the Devil Rays played the
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Last modified: May 25, 2011