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Sports Franchises Edition

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IRS Tax Audit Manual for Sports Franchises

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TABLE OF CONTENTS

  • CHAPTER 1 INTRODUCTION AND LEAGUE INFORMATION
    • Sources Of Information And Guide Emphasis 1-1
    • Emerging Issues And Sports Franchise ISP Team Issue Assistance 1-1
    • Sports League Associations 1-1
    • League Revenue Sharing 1-2
    • The Major Sports League Teams 1-2
    • The National Basketball Association 1-3
    • The National Football League 1-4
    • Major League Baseball 1-5
    • The National Hockey League 1-6
    • League Expansion 1-7
  • CHAPTER 2 GENERAL SPORTS FRANCHISE EXAMINATION TECHNIQUES
    • Overview 2-1
    • General Accounting Considerations 2-1
    • Return Identification And Entity Background Information 2-1
    • Pre-plan And Issue Identification 2-2
    • Intangible Assets 2-2
    • Deferred Revenue And Deposits 2-2
    • Accrued Expenses 2-3
    • Other Deductions 2-3
    • Schedule M-1 2-3 Related Party Transactions 2-4
    • Issue Development 2-4
    • Required Filing Checks 2-5
    • Player Personal Service Corporations 2-5
    • Compliance Strategies 2-6
    • Exhibit 2-1
    • Sample Form 4564, Information Doc. Request 2-7
    • Exhibit 2-2
    • Sample Initial Interview Questions 2-11
  • CHAPTER 3 SPONSORSHIP REVENUE
    • Industry Practice 3-1
    • Audit issue 3-1
    • Tax Law 3-2
    • Prepaid Income 3-2
    • Revenue Procedure 71-21 3-2
    • Tax Law Application 3-4
    • Examination Techniques 3-6
  • CHAPTER 4 BROADCAST REVENUE
    • Industry Practice 4-1
    • National Broadcasting Contracts 4-1
    • Local Broadcasting Contracts 4-1
    • Audit Issue 4-1
    • Tax Law 4-2
    • Services Or Property Right? 4-2
    • Tax Law Application 4-3
    • Examination Techniques 4-5
  • CHAPTER 5 SEASON TICKET REVENUE
    • Industry Practice 5-1
    • Categories Of Seating 5-1
    • Accounting For Season Tickets 5-2
    • Audit Issues 5-2
    • Tax Law 5-2
    • Fixed And Definite Services 5-2
    • Advance Payment Versus Deposit 5-4
    • Tax Law Application 5-6
    • Examination Techniques 5-7
    • Potential Emerging Issue 5-9
  • CHAPTER 6 RELOCATION INCENTIVES
    • Industry Practice 6-1
    • Audit Issue 6-1
    • Tax Law 6-1
    • Tax Law Application 6-3
    • Examination Techniques 6-3
  • CHAPTER 7 STRIKE FUND PAYMENTS
    • Industry Practice 7-1
    • Audit Issue 7-1
    • Tax Law 7-1
    • Tax Law Application 7-3
    • Examination Techniques 7-4
  • CHAPTER 8 STADIUM ISSUES
    • Industry Practice 8-1
    • Stadium Ownership 8-2
    • Overview 8-2
    • Audit Issues 8-2
    • Recovery Periods 8-3
    • Tax Exempt Bond Financing 8-4
    • Examination Techniques 8-5
    • Stadium Leases 8-6
    • Overview 8-6
    • Audit Issues 8-6
    • Leasehold Improvements 8-6
    • IRC Section 467 Rental Agreements 8-7
    • Examination Techniques 8-8
  • CHAPTER 9 AMORTIZATION
    • Overview 9-1
    • Player Contracts 9-2
    • Audit Issues 9-2
    • Tax Law Application 9-2
    • Examination Techniques 9-6
    • Intangible Assets Acquired In The Acquisition Of A Sports Franchise 9-8
    • Audit Issues 9-8
    • Tax Law Application 9-8
    • Broadcasting Rights 9-9
    • Organizational Expenditures And Start-Up Expenses 9-11
    • Audit Issues 9-11
    • Tax Law Application 9-11
    • Potential Emerging Issue For Start-Up Expenses 9-11
  • CHAPTER 10 PURCHASE AND SALE OF A SPORTS FRANCHISE
    • Overview 10-1
    • Audit Issues 10-2
    • Valuation Of The Sports Franchise 10-2
    • The Residual Allocation Method 10-4
    • Player Contracts 10-5
    • Tax Planning Considerations 10-8
    • Economic Reality, Strong Proof Doctrine, And The Danielson Rule 10-9
    • Examination Techniques 10-10
  • CHAPTER 11 LEAGUE EXPANSION
    • Overview 11-1
    • Audit Issues 11-2
    • Tax Law Application 11-2
    • Established Sports Franchises 11-2
    • Expansion Sports Franchises 11-5
    • Examination Techniques 11-8
  • CHAPTER 12 SALES AND EXCHANGES OF INDIVIDUAL PLAYER CONTRACTS
    • Industry Practice 12-1
    • Audit Issues 12-1
    • Tax Law Application 12-1
    • Gains and Losses On Player Contracts Given Up 12-1
    • Tax Basis In Acquired Player Contracts 12-3
    • Examination Techniques 12-5
    • Gains And Losses On Player Contracts Given Up 12-6
    • Tax Basis In Acquired Player Contracts 12-7
    • Potential Emerging Issue on Future Draft Picks 12-7
  • MISCELLANEOUS EXHIBIT A: SPORTS FRANCHISE CITATIONS A-1
    • Code, Regulations, and Committee Reports A-1
    • Service Guidance A-1
    • Revenue Rulings A-1
    • Court Cases A-2
  • EXHIBIT B: INTERNET RESOURCES B-1
  • GLOSSARY G-1
 Don’t forget – The IRS Tax Audit Manual for Sports Franchises is tax deductible as a business expense!