New Orleans Louisiana Saints, Limited Partnership, Benson Football, Inc. Tax Matters Partner - Page 19

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          the Superdome leasehold and $10 million to the nonamortizable NFL           
          franchise.5                                                                 
               After the closing, petitioner engaged the services of                  
          American Appraisal Associates, Inc. (AAA), for the purposes of              
          conducting an independent appraisal of specified tangible and               
          intangible assets associated with the purchase of the team.                 
          Among the tangible assets appraised were furniture, machinery and           
          equipment, uniforms and supplies, camera equipment, game films,             
          and vehicles.  Among the intangible assets appraised were rights            
          to player contracts, an assembled work force of nonplayer                   
          personnel, software, broadcasting and rebroadcasting agreements,            
          the leasehold interest in the Superdome, and the NFL franchise.             
          The AAA appraisal valued the Saints' leasehold interest in the              
          Superdome at $21 million.                                                   
               The Mecom Group generally agreed with the AAA appraisal                
          except as to the value allocated to the Superdome leasehold.                
          Eventually, the Mecom Group and petitioner agreed to allocate $16           
          million to the Superdome leasehold.                                         
               Giving effect to adjustments, and including assumed                    
          liabilities, the contracting parties later determined that the              
          acquisition price under the Sales Contract was $70,494,789.   To            


               5The term “Superdome leasehold” refers to petitioner’s                 
          leasehold interest in the Superdome without distinction between             
          the 1975 Lease and the Revised Lease.  The term is used                     
          interchangeably with the phrase “petitioner’s leasehold interest            
          in the Superdome.”                                                          




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