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whether any portion of the amount petitioner paid for the
purchase of the New Orleans Saints football franchise is
allocable to a leasehold which grants petitioner certain rights
in the Superdome, located in New Orleans, Louisiana. Unless
otherwise indicated, all section references are to the Internal
Revenue Code in effect during the years at issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Petitioner, a Texas corporation owned by Thomas H. Benson,
Jr. (Benson), is the general partner of a Texas limited
partnership known as the New Orleans Louisiana Saints Limited
Partnership (the partnership). The partnership was formed April
23, 1985, and its address and principal place of business is in
Metairie, Louisiana. Since the partnership's inception,
petitioner has been responsible for controlling the management of
the partnership's affairs. During the years at issue, the
partnership was an accrual basis taxpayer and operated with a
December 31 fiscal yearend. The partnership timely filed its
Federal information tax returns for each taxable year at issue.
The Saints Football Team
The New Orleans Saints (interchangeably the Saints and the
team) is a professional football team and has been an official
member of the National Football League (NFL) since 1967. Since
its formation, the team's home city has been New Orleans,
Louisiana. The team failed to experience a winning season during
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