- 3 - tickets for all home games of the Houston Texans football team1 to be played in the new football stadium (now called Reliant Stadium) that was then under construction in Houston, Texas. Petitioner listed his home address and Social Security number on the application. InsurMark paid $7,800 with the application but did not deduct this payment on its 1999 corporate income tax return. On May 23, 2000, petitioner signed a Harris County Stadium permanent seat license agreement, under which the permanent seat license fee was payable in three installments of $7,800, totaling $23,400. Petitioner signed the agreement as “president” but did not specify the entity of which he was president. Petitioner had the exclusive right to use the seat license. He could not transfer the license before the end of May 2003 without the consent of the Harris County-Houston Sports Authority, other than to an immediate family member. Petitioner indicated in the agreement that he was not acquiring the license as an investment and that he intended to use the license himself, and not to distribute it or season tickets to others. InsurMark also paid $7,800 for the permanent seat license in the year ending December 31, 2000, and $7,800 in the year ending December 31, 2001, for a total of $23,400 by the end of 2001. 1 The Houston Texans are a member of the National Football League (NFL).Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011