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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).
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Last modified: May 25, 2011