The club would have to sell players to find the sum United want at a time when owner Bjorgolfur Gudmundsson is trying to make them self-sufficient.
The judgement on the Tevez affair today read: "We have no doubt that West Ham would have secured at least three fewer points over the 2006-07 season if Carlos Tevez had not been playing for the club.
"We think it more likely than not that even over the final two games of the season, West Ham would have achieved at least three points less overall without Mr Tevez."
Sheffield United chairman Kevin McCabe said: "The matter is still legally in process so I do not wish to comment further until we have completed that process."