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estate) and the Nuexco Trading Corp. Bankruptcy Estate (NTC
bankruptcy estate). As of the date of each petition, the
entity’s assets became assets of its bankruptcy estate. Pursuant
to section 1398(d)(2)(D), petitioner elected to terminate his
taxable year as of February 23, 1995. A separate Federal income
tax return was filed for petitioner’s short taxable year February
23 through December 31, 1995.
Among the assets that made up the Benton estate were
petitioner’s interests in three entities that were involved in
the operation and ownership of the Colorado Rockies National
League Baseball Franchise. The three interests included a
limited partnership interest in the Colorado Baseball Club
Limited Partnership (CBCLP), which was the owner of the National
League franchise. In addition, Colorado Baseball Management,
Inc. (CBM), was a corporation entitled to a percentage of the
gross revenues of CBCLP. Lastly, Colorado Baseball, Inc. (CBI),
was the managing general partner in CBCLP.
A second amended plan of reorganization (the plan), dated
August 18, 1997, for petitioner and his related bankruptcy
estates was to be effective on August 31, 1997. Until the August
18, 1997, confirmation of the plan, petitioner served as the
debtor in possession. Among other things, the plan provided that
on August 31, 1997, most of the various bankruptcy estates’
assets would be transferred into a liquidating trust to be
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