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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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