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Tax Audit - Sports Franchises Edition E-Book

Sports Franchises

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E-book Category: Business, Law
E-book Title: Tax Audit - Sports Franchises Edition
Book Description: TABLE OF CONTENTS

CHAPTER 1 INTRODUCTION AND LEAGUE INFORMATION
Sources Of Information And Manual 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 Summary 2-1
General Accounting Considerations 2-1
Return Identification And Entity Background Information 2-1
Preplan And Issue Identification 2-2
Intangible Assets 2-2 Postponed Revenue And Deposits 2-2 Accumulated Expenses 2-3 Another 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 Support REVENUE
Industry Practice 3-1
Audit issue 3-1
Tax Law 3-2 Postpaid Financial gain 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 Bowl ISSUES
Industry Practice 8-1 Bowl Ownership 8-2 Summary 8-2
Audit Issues 8-2
Recovery Periods 8-3
Tax Exempt Bond Funding 8-4
Examination Techniques 8-5 Bowl Leases 8-6 Summary 8-6
Audit Issues 8-6 Estate Improvements 8-6
IRC Section 467 Rental Agreements 8-7
Examination Techniques 8-8

CHAPTER 9 AMORTIZATION Summary 9-1
Player Contracts 9-2
Audit Issues 9-2
Tax Law Application 9-2
Examination Techniques 9-6
Intangible Assets Noninheritable In The Acquisition Of A Sports Franchise 9-8
Audit Issues 9-8
Tax Law Application 9-8
Broadcasting Rights 9-9 Structure 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 Summary 10-1
Audit Issues 10-2
Valuation Of The Sports Franchise 10-2
The Residual Allocation Know-how 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 Summary 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 Noninheritable Player Contracts 12-3
Examination Techniques 12-5
Gains And Losses On Player Contracts Given Up 12-6
Tax Basis In Noninheritable Player Contracts 12-7
Potential Emerging Issue on Futurity 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: Computer network RESOURCES B-1
Gloss G-1

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