Petitioner's Certificate of Organization

Emphasis

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

Lou Groza Boulevard

Cleveland Browns Holdings Co.

New York State Department of Taxation and Finance

New York

TSB

Technical Service

Air Carrier Operating Certificate

Purchaser

Delaware

FAA Regulations

Petitioner

TSB-M-96(14)S

Cleveland Browns Football Co.

the Department of Taxation and Finance

Petitioner

Holdings

Cleveland

LLC

Petitioner

Cleveland Browns Transportation LLC

Ohio

affiliates

Tax Law Defines Commercial Vessels