reasonable accuracy.  It is uncontested that the players' contracts had a 5.25-year useful life.  That the players' contracts had some value cannot be disputed.  The IRS itself initially valued the players' contracts at over $1 million.  The district court, after hearing a substantial amount of evidence in the case, valued the contracts at more than three times the figure fixed by the IRS.  Indeed, it is clear that the players are the primary assets of a professional football club.  Without them, there could not be a game.  As Texas E. Schramm, the widely-respected President and General Manager of the Dallas Cowboys, testified:


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The players are your principal product, and it is players who are responsible for you(r) winning.  They are responsible$7,300,000.  Schramm's valuations were based upon a sliding-scale rating system under which each player was classified in one of five categories, arranged in order of ascending potential player value to the team.  In the lowest category were placed players who had at least made a professional football team, who were valued at $50,000 each.  In the highest category were placed the players who, it was expected, would be starters, who were each valued at $250,000.  In between at $50,000 increments in value were three other categories.  After each of the players whose contracts were acquired by Five Smiths were so valued, Schramm's total came to $7,300,000.  Schramm testified that his valuations were founded on personal knowledge of the veterans and on data