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TRIBUNE MEDIA COMPANY v. COMMISSIONER OF INTERNAL REVENUE

Docket Nos. 20940-16, 20941-16.

T.C. Memo. 2021-122

TRIBUNE MEDIA COMPANY f.k.a. TRIBUNE COMPANY & AFFILLIATES, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. CHICAGO BASEBALL HOLDINGS, LLC, NORTHSIDE ENTERTAINMENT HOLDINGS, LLC, f.k.a. RICKETTS ACQUISITION, LLC, TAX MATTERS PARTNER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed October 26, 2021.

Attorney(s) appearing for the Case

Joel V. Williamson , Thomas Lee Kittle-Kamp , Peter M. Price , Anthony D. Pastore , Daniel S. Emas , James B. Kelly , Scott M. Stewart , John W. Horne , Elizabeth P. Mazzocco , and Phillip M. Goldberg , for petitioners.

Justin D. Scheid , Thomas F. Harriman , William Benjamin McClendon , James M. Cascino , Grubert R. Markley , Rogelio A. Villageliu , and Brandon S. Cline , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

In 2009, Tribune Media Co. f.k.a. Tribune Co. & Affiliates (Tribune) formed Chicago Baseball Holdings, LLC (CBH), with the Ricketts family, with Tribune contributing the Chicago Cubs Major League Baseball team (Chicago Cubs or Cubs) (and related assets) and the Ricketts family contributing...

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