[NU Sports] Tipping Point Near ?
Joe Thiegs
thiegs at umn.edu
Wed May 9 09:36:49 CDT 2007
Actually, it's 80% deductible (I imagine 89% probably was just a typo). For
those who are interested in that kind of stuff, see Treas. Reg.
§ 1.170A-13(f)(14):
"(14) Substantiation of payments to a college or university for the
right to purchase tickets to athletic events. -- For purposes of paragraph
(f)(2)(iii) of this section, the right to purchase tickets for seating
at an athletic event in exchange for a payment described in section
170(l) is treated as having a value equal to twenty percent of such
payment. For example, when a taxpayer makes a payment of $312.50 for the
right to purchase tickets for seating at an athletic event, the right to
purchase tickets is treated as having a value of $62.50. The remaining
$250 is treated as a charitable contribution, which the taxpayer must
substantiate in accordance with the requirements of this section."
Just for background and to make sense of the first cross-reference, §§
1.170A-13(f)(1)-(2) read as follows:
"(f) Substantiation of charitable contributions of $250 or more--
(1) In general. No deduction is allowed under section 170(a) for all or
part
of any contribution of $250 or more unless the taxpayer substantiates
the contribution with a contemporaneous written acknowledgment from the
donee organization. A taxpayer who makes more than one contribution of
$250 or more to a donee organization in a taxable year may substantiate
the contributions with one or more contemporaneous written
acknowledgments. Section 170(f)(8) does not apply to a payment of $250
or more if the amount contributed (as determined under Sec. 1.170A-1(h))
is less than $250. Separate contributions of less than $250 are not
subject to the requirements of section 170(f)(8), regardless of whether
the sum of the contributions made by a taxpayer to a donee organization
during a taxable year equals $250 or more.
(2) Written acknowledgment. Except as otherwise provided in
paragraphs (f)(8) through (f)(11) and (f)(13) of this section, a written
acknowledgment from a donee organization must provide the following
information--
(i) The amount of any cash the taxpayer paid and a description (but
not necessarily the value) of any property other than cash the taxpayer
transferred to the donee organization;
(ii) A statement of whether or not the donee organization provides
any goods or services in consideration, in whole or in part, for any of
the cash or other property transferred to the donee organization;
(iii) If the donee organization provides any goods or services other
than intangible religious benefits (as described in section 170(f)(8)),
a description and good faith estimate of the value of those goods or
services; and
(iv) If the donee organization provides any intangible religious
benefits, a statement to that effect."
More can be found here, in the relevant part of the Code of Federal
Regulations:
http://a257.g.akamaitech.net/7/257/2422/14mar20010800/edocket.access.gpo.gov
/cfr_2003/aprqtr/pdf/26cfr1.170A-13.pdf
This is all part of the deduction substantiation rules, and specifically
part of the "quid pro quo" rule, by which the allowable deduction for a
charitable contribution is limited to the value of the contribution minus
the value of any goods or services received in exchange for the gift
(outside of a de minimis safe harbor for token benefits like a lapel pin or
book or paperweight as a thank-you). In the case of seating benefits, the
value of such benefits is presumed by regulation to be 20% of the value of
the gift, so the deduction is limited to 80% of the gift.
-Joe
-----Original Message-----
From: nwu-sports-bounces at tssi.com [mailto:nwu-sports-bounces at tssi.com] On
Behalf Of Mark Ament
Sent: Wednesday, May 09, 2007 9:07 AM
To: John Labbe
Cc: nwu-sports at tssi.com
Subject: Re: [NU Sports] Tipping Point Near ?
I'm not paying that much for my seats at Louisville football games,
which are at the 40 yard line and close to the field but I do pay a
considerable "donation" for the privilege of purchasing them and I pay
a considerably higher donation for the privilege of purchasing my
basketball tickets which are midcourt. There is a reason why Louisville
is both the highest grossing and highest netting basketball team in the
country while playing in a 50 year old arena with very few luxury
suites. That privilege comes at a very high price. At least it's 89%
deductible. Oh, and for basketball they throw in pregame cheese and
crackers, but you have to pay for the drinks.
John Labbe wrote:
> Yes, NU does have this arrangement. When they added the luxury seats
> up in the press box as part of the Ryan Field renovation in 1997, you
> had to pay a certain fee in addition to the ticket price to be able to
> purchase tickets for those seats.
>
> You can read all about it here:
>
>
http://nusports.cstv.com/boosters/boosters-static-info/nw-boosters-seating.h
tml
>
>
> Anyone ready to pony up between $1000 and $3000 per year per seat
> (that includes all fees, some of which are tax deductible)??
> Personally, even if I could afford it, I would not want to be totally
> indoors for college football. I suppose I could get used to the
> semi-outdoor seats at the $2000 price point.
>
> John
>
>
> On May 8, 2007, at 8:00 PM, Mark Ament wrote:
>
>> And since when did you think they haven't already done PSLs? Most of
>> the "bigger" programs have instituted a variation of the PSL by
>> forcing season ticket holders to "donate" to the school's athletic
>> fund in order to buy season tickets; the better the seats, the
>> higher the donation. It's not called a PSL for the simple reason
>> that as long as it's styled as a donation to the athletic department,
>> it's stilled 80% deductible. I would imagine, although I don't know
>> this for sure, that even NU has this in place for some seats.
>> Mark
>>
>> Abrahamson, Alan (NBC Universal) wrote:
>>> Dennis (and everyone),
>>> I don't dispute for a second your conclusion that it would be sad.
>>> But do I think it's inevitable?
>>> Yes.
>>> And as I say, I don't understand why someone hasn't thought of it
>>> already. Bluntly, it's a function of supply and demand. From where
>>> I sit, it's inevitable that colleges will take up the idea
>>> of making fans pay for PSLs -- personal seat licenses -- like the NFL
>>> teams do. That's a fee you pay just for the right to buy season
>>> tickets.
>>> Club seats and other "premium" seating "innovations" are inevitable,
>>> too.
>>>
>>> -----Original Message-----
>>> From: nwu-sports-bounces at tssi.com [mailto:nwu-sports-bounces at tssi.com]
>>> On Behalf Of Dennis W. Brandt
>>> Sent: Tuesday, May 08, 2007 9:08 AM
>>> To: nwu-sports at tssi.com
>>> Subject: Re: [NU Sports] Tipping Point Near ?
>>>
>>>
>>>> say, Celine Dion or Cirque du Soleil are sold in Vegas.
>>>> You wanna go? OK, it's $250/seat between the 40-yard-lines.
>>>> Field-level? $450. Or whatever.
>>>>
>>>
>>> Alan, the day that happens will be a sad one for American sports. It's
>>> already gone that way in pro sports where the number of businesses
>>> owning season tickets shuts out most fans from good seats. I
>>> personally
>>> would not pay $250 for any Las Vegas attraction whoever it may be, but
>>> there is a major difference here. Most people go to Las Vegas
>>> occasionally or only once. Ergo, they are more willing to pay inflated
>>> prices because it's a once-and-done vacation event. College football
>>> games are another matter. Most people sitting in the stands got in
>>> on a season or a student
>>> ticket. Few are there on a once-and-done vacation. They're
>>> regulars. What's
>>> next? Making the students pay the same price as everyone else?
>>> _______________________________________________
>>> nwu-sports site list
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>>>
>>> _______________________________________________
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>>>
>>>
>>
>> _______________________________________________
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>>
>
>
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