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Petitioner, Naimoli Baseball Enterprises, Inc., is a Florida
corporation and functions as the tax matters partner of the
partnership.
On March 9, 1995, in return for commitments by the
partnership to pay a $130 million franchise fee and to meet other
specified conditions, members of the American and National
Leagues of major league baseball (hereinafter generally referred
to simply as major league baseball) adopted a resolution under
which the partnership was conditionally awarded one of major
league baseball’s expansion franchises. The resolution
established a procedure for the eventual approval of the
partnership and the Devil Rays to participate in major league
baseball.
On March 24, 1995, the partnership and major league baseball
entered into an agreement under which the partnership would
become a full, participating member of major league baseball upon
the satisfaction, no later than November 30, 1997, of the
conditions specified in the above resolution and agreement.
Under the resolution and agreement, the major requirements
and conditions that the partnership had to satisfy prior to
receiving final approval for participation in major league
baseball are described below:
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Last modified: May 25, 2011