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