TEMPE, ARIZ., DEC. 31 -- The Florida State Seminoles and Nebraska Cornhuskers come together New Year's Day with some regrets. The Fiesta Bowl usually is a mighty nice postseason reward for two highly ranked college football teams, but not for these two. Not this year.

No. 3-ranked Florida State figures it is a measly two-point conversion pass away from being undefeated and playing for a national title. No. 5 Nebraska figures it is two missed tackles away from being Florida State's opponent. Take those could-have-beens and move this game 2,000 miles east, into Miami's Orange Bowl, and the Seminoles and Cornhuskers would feel just dandy.

But the reality, the pain of the situation is that the winner of this 17th Fiesta Bowl (WRC-TV-4, WMAR-TV-2, 1:30 p.m.) could be the best team in the nation and still not be any higher than No. 2 in the final wire service polls that determine the national champion.

As good as the matchup is -- between two 10-1 teams ranked in the top 10 in every important statistical category -- the game is virtually insignificant. These days, when Nos. 1 and 2 seem to get together every year, No. 3 versus No. 5 just won't cut it.

The Seminoles knew on Oct. 3 that if they missed that two-point conversion pass against Miami, their shot at winning a national title would slip away. And the Cornhuskers knew on Nov. 21 that if they let the Sooners break off a long run or two, they would have to settle for something less.

So, Florida State and Nebraska come to Sun Devil Stadium first hoping to win, then hoping that a first-rate tropical hurricane forces top-ranked Oklahoma and second-ranked Miami to play the worst 0-0 tie on record at the Orange Bowl.

Regardless of which team wins in Miami, there are those who believe Florida State is the best team in the nation. Seminoles Coach Bobby Bowden, not one to toot his own horn, is one of them.

"If we were to beat Nebraska, then we're probably as good as anybody in the country even though we couldn't win the national title," Bowden said today. "People who saw us play Miami, unless they are are lying to me, thought we were better {despite losing, 26-25}.

"If Miami and Oklahoma get careless down there and play a sloppy tie -- which I'm not counting on one bit -- then somebody might jump over them into No. 1; Syracuse {11-0, fourth-ranked and playing in the Sugar Bowl}, or us, or Nebraska if one of us happens to win big.

"But a tie in the Orange Bowl won't even be in our pregame speech," he said. "We'll be fighting for No. 2, I guess. And if something strange happens there, it just happens."

Something pretty good could happen in the Fiesta, before a sellout crowd of more than 70,000 in the same Sun Devil Stadium where Penn State upset top-ranked and unbeaten Miami last Jan. 2 to claim the national title.

Florida State, which never has finished higher than No. 5, has scored 40 or more points six times this season and allowed fewer than 20 points nine times in 11 games. The Seminoles are renowned for wide-open and explosive offense, and rightfully so since balding and oft-injured quarterback Danny McManus, who has won 18 of his 20 starts, is healthy and hot.

But the Seminoles defense, according to Bowden, is what has made the difference between a typical Florida State put-'em-up, give-'em-up team and one that might be the best in the country. Nebraska will have to find a way to attack a defense with Butkus Award-winning linebacker Paul McGowan and the nation's premier cornerback, Deion Sanders.

The teams have two running backs who couldn't be closer in statistical profile. Florida State's Sammie Smith has 172 carries for 1,230 yards, while Nebraska's Keith (End Zone) Jones has 172 carries for 1,232 yards. They tied for the nation's best yard-per-carry average, with 7.2.

Jones' performance is just part of the reason Cornhuskers Coach Tom Osborne, whose team is making its 15th consecutive bowl appearance, believes this team was as good for the first nine weeks of the season as any team he has had in Lincoln.

Osborne, like most coaches in prebowl talk, likes to make the opposing team sound like the '67 Packers. But Osborne could be right on target this time, saying earlier this week, "Florida State may very well prove to be the best. I think there is no question that they should probably be in the Orange Bowl. Miami has a good team and they won the game, but if you look at it in perspective, Florida State had a better team that day. I think they had 400 and something yards to Miami's 300 or so . . . .

"In talking with Barry Switzer and other coaches prior to our game with Oklahoma, the feeling was that whichever one of us {the Oklahoma-Nebraska loser} went to the Fiesta Bowl quite likely had the toughest job, and I believe that sincerely."

Osborne, however, hasn't brought a bunch of patsies. Many of his players were on the Cornhuskers team that whipped Florida State, 34-17, last season in Lincoln.

That lopsided loss is one reason Bowden says he won't have to do "a selling job" to get his players fired up.

Florida State has lost both its previous New Year's Day games (to Oklahoma in 1979 and '80). And one never knows what might happen in Miami.