Opinion: If they played in the National Football League, the Philadelphia Stars would win at least half their games and finish as high as second in either of the two Central divisions.

Prediction: As Baltimore Stars, as Sun Belt Stars, or as Stars shining from somewhere, the 1984 U.S. Football League champions will get a chance to make that happen within three years.

This latest war waged within pro football cannot last a whole lot longer. Too many USFL teams are losing too much money for the league to be viable more than a few more seasons; enough strong teams will relocate in natural NFL expansion areas to force some sort of merger.

Simply put, merger by the start of the 1987 season would seem to best satisfy two basic instincts of all team owners: need and greed. They need to stop diluting each other's product, and to be able to hold up television for as much money as possible.

The latter consideration requires a united force, Donald Trump and Jack Kent Cooke helping hold all the cards against the networks when the NFL deal expires after the 1986 season.

The only thing compelling about the USFL has been all those wonderful players it has coaxed from the NFL's clutches: Herschel Walker, Marcus Dupree, Trumaine Johnson, Jim Kelly, Steve Young and at least four dozen more.

Now that the USFL has said it will switch to fall ball in the 1986 season, the major intrigue is where its superior teams will end up playing. The fight will not be for survival so much as for territory.

Baltimore and Oakland, two towns jilted by the NFL, loom as bonanzas. One or two other teams are said to be trying to beat the Stars to Baltimore; the Oklahoma and Oakland franchises are combining -- in Oakland.

Surely with an eye toward reentry into the NFL, George Allen has said he will return to guide the Arizona Wranglers; four other USFL teams in growing football hotbeds -- Memphis, Birmingham, Jacksonville and Tampa Bay -- already are successful.

Very likely, the Stars are the better team in Philadelphia, and the Bandits better run in Tampa than its NFL entry. So when the NFL needs to expand, it will find happy and prosperous teams waiting. More important, it will find an enormous core of fans already thrilled and reasonably sophisticated about pro football.

This presumes a great deal about NFL owners, including ability to forgive, if not forget, the USFL costing them millions these last several years. The temptation to bleed the interlopers dry will be close to irresistible for many.

Also, the NFL owners will be asking themselves this question: If some of us are losing money now, why should we share revenue with four to eight additional teams?

How anyone drawing $14.2 million a year just from television can be in the red is a mystery to at least one fellow who did not sleep through every economics class in college. But then how teams such as New Orleans and Tampa Bay can be so consistently inept is equally startling.

The NFL line is that it sells players to an expansion team, several dozen pretty awful ones who can be amortized for tax purposes over four-plus years.

My theory is that an NFL owner buys exclusivity more than anything, the right to share in a unique kind of acceptable cartel with very few labor problems for at least the near future.

Franchises in the early '80s are worth 10 times what they were in the middle '60s. A man might be able to turn his money over that often in that time frame some other way, but surely not with so much fun and attention.

That's the gamble for such as Trump. Say he will spend $20 million on his Generals the next two seasons; he probably can write off half that -- and, with a merger, have an investment worth at least $60 million.

Antitrust laws are involved, of course, but they seem no more of a threat than, say, gang-tackling Eric Dickerson on an end sweep. Tough, but not impossible. The right combination of building a team, through draft choices and free agents, and coaching it creates winners in a hurry. Paul Brown demonstrated that in an outlaw league in the '40s, as did Al Davis and Lamar Hunt in the '60s.

Teams do not need early first-round draftees over a period of years to become champions, although that certainly helps; Bobby Beathard and Joe Gibbs created a Super Bowl winner for the Redskins with judicious use of relatively low draft choices.

The Stars have done much the same thing, constructed a foundation with expensive players such as Kelvin Bryant and some offensive linemen and added style and more substance with rather cheap material.

NFL and USFL owners adamant about a fight to the finish will be wise to examine how the colleges have suffered financially by being stubborn and uncompromising.

Two rival brands of soap fetch perhaps half as much as one unrivaled. That realization just might wipe out large layers of bitterness.