Legal Opinion

Milenbach v. Commissioner

United States Tax Court

Decided March 28, 1996No. Docket Nos. 28514-92, 1571-93, 1572-93, 1573-93, 1574-93, 12129-94Published

P's were partners of the Raiders, a professional football team that received municipal funds repayable only from specific sources of revenue.

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P's were partners of the Raiders, a professional football team that received municipal funds repayable only from specific sources of revenue. The partnership also received funds from settlement of a lawsuit brought by the City of Oakland. 1. Held: Amounts received from the Los Angeles Memorial Coliseum Commission as "loans", to be repaid from revenue received from luxury suites, are taxable when received, because the obligation to repay was not unconditional. 2. Held, further, damages received from the City of Oakland were not allocated to goodwill or franchise value and are thus taxable. 3.…

1Opinion of the Court

SHELDON R. AND PHYLLIS MILENBACH, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Milenbach v. Commissioner

Docket Nos. 28514-92, 1571-93, 1572-93, 1573-93, 1574-93, 12129-94

United States Tax Court

106 T.C. 184; 1996 U.S. Tax Ct. LEXIS 8; 106 T.C. No. 8;

March 28, 1996, Filed

Decisions will be entered under Rule 155.

P's were partners of the Raiders, a professional football team that received municipal funds repayable only from specific sources of revenue. The partnership also received funds from settlement of a lawsuit brought by the City of Oakland.

1. Held: Amounts received…

2Cases cited36 opinions

  1. Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
  2. United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
  3. United States v. Kirby Lumber CoSupreme Court of the United States · 1931
  4. Michael L. Rockwell, and Regina Rockwell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
  5. Raytheon Production Corp. v. Commissioner of Int. Rev.Court of Appeals for the First Circuit · 1944

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