Milenbach

The Commissioner of Internal Revenue determined deficiencies in Petitioners-Appellants Sheldon and Phyllis Milenbach’s federal income taxes for the years 1980 through 1982. The Commissioner also issued notices of Final Partnership Administrative Adjustments determining adjustments to the income of the Los Angeles Raiders, a California Limited Partnership, for the years 1983 through 1989. Petitioners (collectively the “Raiders”) appeal from the Tax Court decisions affirming the contested determinations. See Milenbach v. Comm’r, 106 T.C. 184 , 1994 WL 891961 (1996).

The Raiders own a professional football team and belong to the National Football League (the “NFL”). Prior to 1980, the Raiders played their home games at the Oakland-Alameda County Coliseum (the “Oakland Coliseum”). The Raiders’ lease of the Oakland Coliseum expired at the end of the 1979 NFL season. During 1979, the Raiders negotiated with the Los Angeles Memorial Coliseum Commission (the “LAMCC”) to allow the Raiders to begin playing their home games in the Los Angeles Memorial Coliseum (the “LA Coliseum”). In 1980, the Raiders announced that they intended to leave Oakland and play their home games at the LA…