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IRS CLAIM OF $7M IRKS DEVIL RAYS; LEADS TO TAX COURT APPEAL

          The Devil Rays ownership group, led by Managing General
     Partner Vince Naimoli, is "appealing" to U.S. Tax Court to
     overturn an IRS finding that the team "underreported its
     income by more than" $7M in '95 and '96, according to Jerry
     Moskal of the TAMPA TRIBUNE.  The dispute "involves how the
     partnership accounted for income from advance sales of
     tickets and suites at Tropicana Field, and from sponsorships
     and promotional events."  The team "argued the income should
     be recognized" in '98, when it began play.  But the IRS
     "ruled the income had to be reported in the years the
     payments were received."  If the IRS' ruling is upheld, the
     partnership's owners would be subject to additional taxes on
     their share of the proceeds."  It's "not clear how much
     additional tax the owners would owe."  The team says the
     "advance sales were recorded as a liability on the team's
     books, rather than income, because there were no assurances
     at the time that the team would ever take the field," as the
     franchise had to reach "certain conditions."  If the IRS and
     the team can't reach a settlement, the case "could go to
     trial before a tax court judge" (TAMPA TRIBUNE, 7/27). 

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