§1056 — Repealed. Pub. L. 108–357, title VIII, § 886(b)(1)(A), Oct. 22, 2004, 118 Stat. 1641]

1056, I.R.C., applies and would limit the amortizable basis in the player contracts, even though the contracts were acquired through purchase of an interest in a partnership. Alternatively, R contends that if sec. 1056, I.R.C., does not apply to partnership transactions involving sports franchises, the partnership's basis would be less than claimed under subch.

423 (1997), this Court used the entity approach for purposes of applying section 1056.

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 section 1056 in addition to, in conjunction with, or instead of the subchapter K partnership provisions.

. We recognize that in several instances courts have found the entity approach better than the aggregate approach. For example, in P.D.B. Sports, Ltd. v. Commissioner, 109 T.C. 423 (1997), this Court used the entity approach for purposes of applying section 1056. Similarly, in Madison Gas & Elec. Co. v. Commissioner, 72 T.C. 521, 564 (1979), affd. 633 F.2d 512 (7th Cir. 1980), this Court and the Court of Appeals for the Seventh Circuit applied the entity approach in determining whether expenses

1056(d)(1) (1994). In addition, once a participant's benefit becomes vested, it is nonforfeitable under ERISA. Bd. ofTrs. ofthe Sheet Metal Workers' Nat'l Pension Fund v. Commissioner, 117 T.C. 220, 228 (2001), affd, 318 F.3d 599 (4th Cir. 2003). In sum, a participant in a section 401(a) plan may not assign or alienate his or her benefit, and

1056(d), 88 Stat. 829, preempted a predeceasing nonemployee spouse’s right under California community property law to leave her interest in her former husband’s pension to a third person in her will). The U.S. Court of Appeals in Ablamis did not consider the Federal tax consequences of application of community property law or hold that communi

72(t)(1) provides: Imposition of additional tax.--If any taxpayer receives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer’s tax under this chapter for the taxable year in which such amount is received shall be increased by an amount equal to 10 percent of the portion of such amount which is includible in gross income.

1056(d)(3)(J) (1994). Sec. 72(t)(l) provides: (1) IMPOSITION OF additional TAX. — If any taxpayer receives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer’s tax under this chapter for the taxable year in which such amount is received shall be increased by an amount equal to 10 percent of the portion of

1056 (West 1982). We have only the Grant Deed dated "as of January 1, 1992" and notarized on November 17, 1994, in the record. Even if the deed were effective retroactively to January 1, 1992, Coastline did not have title to Saddle Rock on June 21, 1991, when petitioner transferred $188,000 from Coastline's account to petitioners' personal acc

1056(d)(1) (1994). Section 1.401(a)-13(c)(1), Income Tax Regs., provides: (c) Definition of assignment and alienation--(1) In general. For purposes of this section, the terms “assignment” and “alienation” include-- (i) Any arrangement providing for the payment to the employer of plan benefits which otherwise would be due the participant under