New Orleans Louisiana Saints, Limited Partnership, Benson Football, Inc. Tax Matters Partner - Page 30

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          Lease by 1 year.  According to respondent, the 1975 Lease was               
          unfavorable because it lacked generous revenue incentives                   
          consistent with the industry trend.                                         
               We find respondent's argument unconvincing.  By focusing on            
          the duration of the benefit generated by the Second Lease                   
          Amendment, respondent is simply attempting to broaden our focus             
          with respect to the evaluation of the 1975 Lease.  As previously            
          noted, we are not persuaded by respondent's attempt to convince             
          us to consider proposed lease values contained in bids made by              
          cities interested in attracting the Saints.                                 
               Under the second factor, we are to consider the location of            
          the Superdome.  Again, respondent seeks to define the "market"              
          and expand the focus of our evaluation to include those cities              
          that had expressed an interest in hosting the Saints.                       
          Petitioner, on the other hand, contends that we limit our focus             
          to Louisiana, and specifically New Orleans.  We are inclined to             
          agree with petitioner.  At issue here is the fair market value of           
          the Superdome lease, and, as previously noted, the record does              
          not support an analysis of the comparability of the Superdome and           
          facilities located in other cities.  The Superdome is located in            
          New Orleans, and we restrict our focus accordingly.                         
               Under the third factor, we consider the duration of the 1975           
          Lease.  We recognize that the lease was due to expire prior to              
          the start of the 1985 football season but note that the lease               
          provided for two successive 5-year renewal options.  In our view,           




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