Selig v. United States

Bud Selig (plaintiff) purchased a Seattle baseball franchise for $10.8 million, allocating $10.2 million of that price to the value of 149 player contracts based on multiple appraisals valuing them at roughly $10 million using franchise-market comparisons, and amortized that amount over the players' five-year useful lives for tax purposes; the government's own appraisals, based on individual player values rather than the franchise-sale market, found much lower figures ($3.2 million and $5.1 million). The IRS disallowed the deduction, Selig paid the resulting deficiency and sued for a refund, the district court ruled the amortized deduction was proper, and the government appealed.