MEMORANDUM FINDINGS OF FACT AND OPINION
WRIGHT, Judge:
Respondent issued five notices of final partnership administrative adjustments to petitioner, determining adjustments for taxable years 1985 through 1989. After concessions by the parties, the sole issue for consideration is whether any portion of the amount petitioner paid for the purchase of the New Orleans Saints football franchise is allocable to a leasehold which grants petitioner certain rights...
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