SBD/7/Franchises

BOWLEN WINS TAX RULING AGAINST IRS ON BRONCOS PURCHASE

          A federal tax court "has upheld the way" Broncos Owner
     Pat Bowlen valued the team when he purchased it in '84,
     according to the ROCKY MOUNTAIN NEWS.  The decision "allows
     him to retain" a $1.35M tax deduction "that has been in
     dispute for nine years."  The "key issue" involved whether
     Bowlen's acquisition of the team was "technically the
     purchase of a franchise or the purchase of a partnership." 
     By contending that it was the purchase of a partnership, he
     was able to write off $36.1M in player contracts against
     future profits.  The IRS "questioned the tactics," leading
     to Bowlen filing a complaint (ROCKY MOUNTAIN NEWS, 1/7).

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