the Atlanta franchise deal as it is now in hindsight.  Five Smiths was obviously not going to forego the benefits of the League television pool especially when television revenues were an important inducement for the purchase of the franchise.


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Taxpayers also contend that, even assuming arguendo that Five Smiths did acquire the right to share in future television income, in addition to the rights under the four-year CBS contract, the latter constituted a separate asset which was depreciable.  Taxpayers reason that Five Smiths' interest in the CBS contract had both a proven value (the $4,277,043 present value of the club's guaranteed income under the contract) and a definite four-year limited useful life.  But as the Government correctly points out, the rights under the CBS contract werefinal argument on the issue of television rights that, since the CBS contract did not contain a renewal option, any further television contracts would require new bargaining between the networks and the NFL teams.  Taxpayers argue on that basis that future rights do not extend the useful life of the four-year television contract.  This argument is also without merit.  Although the CBS contract provided a measure of the value of Five Smiths' television rights, the source of those rights was the Atlanta agreement.  Indeed, the CBS contract preceded the entry into the League of the Atlanta Club.  Five Smiths' right to share in the revenues from network television contracts is indefinite in duration, and continues as long as Atlanta remains a member of