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Patrick Bowlen (Bowlen), after graduating from the University of Oklahoma law school, practiced law for 2 years in Calgary, Canada. In particular, the controversy centers on whether section 1056 was intended to apply where the buyer acquires a partnership interest in a partnership holding player contracts.
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Conversely, respondent contends that section 1056 applies to limit amortization to an amount equal to the seller's basis, plus any gain recognized by the seller. Petitioner contends that the partnership provisions apply exclusively and would, in this case, permit the amortization of the fair market value of the player contracts. After concessions, the sole issue remaining for our consideration is whether the partnership, for purposes of determining the amortizable basis in player contracts, is subject to sectionġ056 1 in addition to, in conjunction with, or instead of the subchapter K partnership provisions.
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Among other adjustments, respondent disallowed amortization in the amounts of $1,878,056 and $259, respectively, claimed with respect to professional football player contracts. Respondent issued notices of final partnership administrative adjustments to P.D.B. SPORTS, LTD., Bowlen Sports, Inc., Tax Matters Partner, Petitioner,ĬOMMISSIONER OF INTERNAL REVENUE, Respondent. G & S men's, women's and children's clothing and footwear namely, wool hats, baseball caps, visors, headbands, wristbands, T-shirts, tank tops, pajamas, golf shirts, sweaters, sweatshirts, jackets, neckties, cloth bibs, jerseys, coats, robes, sneakers, gloves, scarves, mittens, aprons, down jackets, leather jackets, shorts, sweatpants, jeans, pants, socks, underwear, bathing suits. G & S trading cards, posters, magazines relating to football, calendars, wrapping paper, paper stickers, paper napkins, books relating to football, notepads. G & S Toys and sporting goods, namely, plush toys, stuffed toy animals, play figures, golf balls, golf bags, golf club covers, footballs, toy banks, board games relating to football, Christmas tree ornaments, billiard balls, dart boards, playing cards and miniature replica helmets.
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G & S Jewelry, watches, clocks, pins being jewelry, necklaces, bracelets, charms, precious metal money clips, rings being jewelry, collectible coins, coins of precious metal, pendants and key chains made of precious metal.
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G & S Football helmets, cell phone covers, decorative magnets, pre-recorded DVDs featuring the sport of football, computer game software and disks, mouse pads. G & S Promotion of entertainment services in the nature of professional football games and exhibitions entertainment services, namely, providing a website featuring multimedia material in the nature of television highlights, interactive television highlights, video recordings, video stream recordings, interactive video highlight selections, audio recordings, sports news and information, team and player statistical information, game schedules of others, all in the field of professional football. G & S Men's, women's and children's clothing, namely, fleece tops and bottoms, caps, headwear, t-shirts, sweatshirts, shorts, tank tops, sweaters, pants, jackets, turtlenecks, jumpsuits, golf shirts, jerseys, wristbands, warm up suits, swimwear, wind resistant jackets, raincoats, parkas, ponchos, ties, suspenders, cloth bibs, sleepwear, namely, robes, night shirts and pajamas, gloves, mittens, knit hats, scarves, aprons, headbands, ear muffs and underwear. Since they have made filings for BRONCOS and BRONCOS COUNTRY, as well as filings for their mascot name and their stadium salute, the ‘MILE HIGH SALUTE’. Like most NFL teams, they initially filed for their name, logos, and uniforms. The Broncos have a rather conservative number of trademark filings that started in June of 1970. They have two mascots, Miles, and the live animal mascot, Thunder.
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Initially, the mascot was a ‘bucking bronco’, which has now evolved into a side head profile of the bronco. The team’s mascot has also gone through some changes. The team has called their color scheme “Orange Crush”, which they have filed a trademark for. Other than transitioning from a royal blue to a navy, the team has stuck with the same color scheme. Two years later, they transitioned their colors to orange, blue and white. In 1960, the team debuted with very flashy uniforms, sporting a white and mustard yellow jersey and brown helmets and pants.
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Since, the team has become one of the most successful teams in the NFL and have had several members that have been inducted in the Pro Football Hall of Fame, such as, John Elway, Shannon Sharpe, and Terrell Davis. In the beginning the team had little success, not having a winning season until 1973. The Denver Broncos have competed in the National Football League since 1959, as a member of the AFC West division.