Tampa Bay Devil Rays, Ltd., Naimoli Baseball Enterprises, Inc., Tax Matters Partner - Page 5




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          no later than November 30, 1997, be subject to final approval by            
          the members of major league baseball.  If approved, the                     
          partnership would then be permitted to sign major league baseball           
          players and to field a major league baseball team for                       
          participation in major league baseball beginning with the 1998              
          major league baseball season.                                               
               On April 28, 1995,1 the partnership executed with the city             
          of St. Petersburg, Florida, an agreement for the renovation,                
          management, operation, and use of the Thunderdome for major                 
          league baseball beginning with the 1998 season.  Renovations to             
          the stadium began in 1995.                                                  
               From March 1995 through early November 1997, representatives           
          of the partnership were entitled to attend the periodic meetings            
          of the members of major league baseball.  The partnership,                  
          however, had no vote at the member meetings, was not yet                    
          permitted to field a major league baseball team, and generally              
          was not yet authorized to participate or share in major league              
          baseball’s central fund (i.e., the revenue and liabilities                  
          associated with the play each season of major league baseball).             
               Beginning in 1996, the partnership did receive limited                 
          funds from major league baseball in connection with third-party             


          1    Dates for events reflected in our findings of fact conform             
          to the dates reflected in the parties’ stipulation of facts and             
          other trial evidence.  Some of those dates differ by a day or two           
          from dates for the same events reflected in the mass media.  See,           
          e.g., http://www.tampabay.devilrays.mlb.com.                                




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