Research Problem 1. Sidney owns a professional football franchise. He has received an offer of $80 million for the franchise, all of the football equipment, the rights to concession receipts, the rights to a stadium lease, and the rights to all of the player contracts he owns.

Most of the players have been with the team for a long time and have contracts that were signed several years ago. The contracts have been substantially depreciated. Sidney is concerned about potential § 1245 recapture when the contracts are sold. He has heard about

“previously unrecaptured depreciation with respect to initial contracts” and would like to know more about it. Find a definition for that phrase, and write an explanation of it.