Berea

Petitioner's Certificate of Organization

Emphasis

Petitioner

Holdings

Delaware

New York State Department of Taxation and Finance

New York

Office of Tax Policy Analysis Sales Tax Technical Services Division March 6, 2006

Air Carrier Operating Certificate

Technical Service

TSB-M-96(14)S

Cleveland Browns Holdings Co.

Petitioner

the Department of Taxation and Finance

Purchaser

FAA Regulations

Cleveland Browns Football Co.

Lou Groza Boulevard

TSB

Cleveland

Petitioner

Tax Law Defines Commercial Vessels

Suffolk County

affiliates

Cleveland Browns Transportation LLC