- 19 - constitute income to petitioner, but rather when the deposits should be included in the partnership’s income under the clear reflection of income standard of section 446. Respondent notes the partnership’s deduction in 1995 and 1996 of expenses relating to its minor league baseball operation, to general operations, and to interest on the financing obtained to pay the $130 million franchise fee. We agree with petitioner that the partnership’s deduction in years prior to 1998 of minor league baseball expenses, of general startup operating expenses, and of current year interest expense is not inconsistent with the deferral until 1998 of deposits relating specifically to the Devil Rays’ 1998 major league baseball season. With regard to the $125,000 sponsor fee that the partnership received in 1996, the evidence is incomplete and does not adequately establish any basis for deferring the sponsor fee to 1998. We sustain respondent’s determination that the sponsor fee should be included in petitioner’s income when received in 1996. Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19
Last modified: May 25, 2011