P.D.B. Sports v. Commissioner
United States Tax Court
An individual purchased more than a 50-percent interest in a partnership, that owned and operated a professional sports franchise.
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An individual purchased more than a 50-percent interest in a partnership, that owned and operated a professional sports franchise. Partnership's presale basis in player contracts was 6X. Because more than 50 percent of Partnership's ownership had changed, P contends that sec. 708, I.R.C., causes a termination and triggers the partnership basis provisions causing a stepped- up basis (to fair market value) in the player contracts to 36X. Partnership claimed amortization deductions using the 36X basis. R contends that sec. 1056, I.R.C., applies and would limit the amortizable basis in the player…
1Opinion of the Court
Gerber, Judge:
Respondent issued notices of final partnership administrative adjustment to P.D.B. Sports, Ltd., for the taxable years 1989 and 1990. Among other adjustments, respondent disallowed amortization in the amounts of $1,878,056 and $259,255 for 1989 and 1990, respectively, claimed with respect to professional football player contracts. After concessions, the sole issue remaining for our consideration is whether the partnership, for purposes of determining the amortizable basis in player contracts, is subject to section 10561 in addition to, in conjunction with, or instead of the…
2Cases cited25 opinions
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