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Specifically, records show that from 2009-2015, the Club made improper and/or unclear accounting entries or adjustments that reduced shareable revenue in two ways: sponsor, broker, and customer misclassification. Working with forensic accountants, the investigation identified, for the 2011-2015 season, approximately $9 million protected by misclassifying shareable revenue held in accounts related to certain large sales to sponsors and brokers and clients (“Sponsor, Broker and Client Misclassification”). A significant portion, approximately $7 million, consists of revenue from NFL ticket sales or unfairly underpriced deals with sponsors or revenue from facilities associated with NFL games that were turned into special events. Concurrent emails discussing these revenues indicated a clear intent to falsify revenue records to avoid sharing. For example, a July 2010 communication suggests that commanders determined that a “less obvious” way to “avoid VTS implications” on an NFL hospitality tent sold to a sponsor was to redirect revenue ($17,773) to a hospitality tent for a Virginia Tech college game, even though “the deal does not reference VTS” and they “would not”. [sic] Send them tickets.” When an employee asked if it was “kosher” to “just redirect”[] a non-shareable revenue [sic] department,” replied a senior official, “it [sic] OK.” Other sponsors, brokers, and customers misclassifications appear to have included: (i) selling NFL tickets through brokers or on Internet ticket sales platforms and then classifying the resulting revenue as special event revenue; (ii) reclassifying revenue from NFL tickets as non-shareable revenue in hospitality accounts (for special events); and (iii) recording forfeited security deposits on NFL season tickets as “miscellaneous income.” 24 Deferred Income Transfers. In order to avoid improperly sharing of NFL revenue given the approved use of special event accounts, a forensic accounting review was performed on certain transfers of revenue from NFL-related accounts to special event accounts. This review revealed that, for the 2009-2015 seasons, $44.49 million of ticket, parking, license and other revenue originally recorded by clubs in an account called NFL-related revenue was retained. appears to have been transferred to non-shareable special event accounts (“deferred income transfers”). The club has recently provided information that the club’s accounting practices include shareable football-related and non-shareable special event revenue in the parent account. Nevertheless, due to the absence of available accounting documentation to support the appropriateness of the vast majority of these transfers and inconsistencies and apparent weaknesses in the Club’s historical accounting practices, the investigation could not conclude how many of the deferred income transfers represented legitimate non-shareable revenue or reflected improper revenue preservation practices identified in the sponsor, broker and customer misclassifications. To determine whether, in fact, the deferred income transfer included unreported shareable revenue, we identified 24 general account journal specific to the club, these categories of potentially misclassified revenue occurred in the following seasons: 2011 ($0.33 million); 2012 ($3.00 million); 2013 ($1.79 million); 2014 ($1.88 million); 2015 ($2.03 million). 16