Oren L. Benton - Page 4

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         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 tax year as of            
         February 23, 1995.  A separate Federal income tax return was                 
         filed for petitioner’s short tax 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 settlement agreement was entered into during June 1997 by             
         petitioner; Beverly A. Benton (petitioner’s wife); Oren L.                   
         Benton, as the debtor in possession of the Benton estate; the NTC            
         bankruptcy estate; and the Internal Revenue Service.  That                   
         settlement agreement incorporated by reference a March 5, 1997,              
         letter offer from petitioner, Mrs. Benton, the Benton estate, and            
         the NTC bankruptcy estate to the U.S. Department of Justice (DOJ)            
         and DOJ’s April 1, 1997, letter of acceptance of that offer.  As             






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