New Orleans Louisiana Saints, Limited Partnership, Benson Football, Inc. Tax Matters Partner - Page 29

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          to their respective cities.  Similarly, respondent explains that            
          the city of Philadelphia offered to defer all stadium rental                
          payments for a period of 10 years if the Saints agreed to                   
          relocate to Philadelphia.  Hence, according to respondent and in            
          light of these proposed rental terms, the terms of the 1975 Lease           
          after the Second Lease Amendment were not more favorable to the             
          lessee than those of comparable stadium leases.                             
               We are not persuaded by respondent's attempt to expand our             
          focus with respect to the fair rental value of the 1975 Lease.              
          Not only are the lease values advanced by respondent merely                 
          proposals, the record is insufficient for an analysis of the                
          comparability of the facilities located in other cities.                    
               Respondent also attempts to refute petitioner's argument by            
          directing our attention to the duration of the period during                
          which the benefits stemming from the terms of the Second Lease              
          Amendment were realized by the Mecom Group.  Specifically,                  
          respondent maintains that the Mecom Group experienced little                
          benefit from the terms of the Second Lease Amendment because that           
          amendment preceded the sale of the team by 1 year.  Additionally,           
          respondent maintains that had the Mecom Group been unable to sell           
          the team, it would not have benefited from the terms of the                 
          Second Lease Amendment for a period exceeding 1 year unless it              
          exercised its option to extend an otherwise unfavorable lease.              
          This is so, respondent explains, because the Second Lease                   
          Amendment preceded the expiration of the primary term of the 1975           




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