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MrBig

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  1. The middle of the field is wide open with only the ref standing there. Not only does the camera add 10 pounds, it makes Quinn’s throwing windows look wider than they actually appear.
  2. This is a good article that discusses the tax implications of NIL collectives. https://midmichigannow.com/amp/sports/unintended-consequences-how-nil-in-college-sports-has-raised-questions-about-nonprofits Unintended consequences: How NIL in college sports has raised questions about nonprofits Monday, Jul 29th 2024 NEW YORK (AP) — Three years into the new age of college sports, where athletes are allowed to profit from their successes through name, image and likeness deals, everyone is still trying to find out what the new normal will be. Greg Sankey, commissioner of the Southeastern Conference, called it “uncharted waters of change” in July at SEC Media Days in Dallas, as college football season approaches. "Anytime you go through a reset, it is difficult,” said Sankey, whose conference not only includes perennial powerhouses Georgia and Alabama, but, as of this year, Texas and Oklahoma, as well. Those uncharted waters aren't limited to football. The complicated, often murky, world of NIL has touched not just every corner of college sports, but also had an unanticipated effect on the charitable organizations that popped up to help players secure these sponsorship deals. The basic question NIL raises for nonprofits is: What is charitable about paying college players? To unravel how NIL deals in college sports have anything to do with the nature of tax-exempt organizations, we have to go back to 2021. That’s when a Supreme Court decision forced the NCAA to allow players to be paid for the use of their name, image and likeness. The ruling allowed players to finally enter into sponsorship and endorsement deals — including everything from the much-anticipated EA Sports College Football 25 video game to promotional appearances for local restaurants and car dealerships. Fallout from the Supreme Court decision continues, with rules governing NIL deals evolving in response to new lawsuits and state laws. Initially, the NCAA prohibited colleges and universities from directly paying their players, though that may soon change. But to bridge that gap, a cottage industry of outside groups popped up to facilitate contracts between boosters and athletes. Some of those outside groups formed as companies — where fans gave them money and the groups, after taking a small cut, passed it on to the school’s athletes. In return, the athletes are supposed to perform some service for the group, like autographing merchandise or posting on social media. Other groups incorporated as nonprofit organizations and applied successfully to the Internal Revenue Service for tax-exempt status. “The worry was there’s going to be a narrative perception from the public that this is just greedy athletes, right? So we've got to clean that up, and the way you do that, as always, is nonprofit work, charity work,” said Darrell Lovell, assistant professor of political science at West Texas A&M University, who has written a book about NIL initiatives. What percentage of these new organizations are for-profit and what percentage are nonprofit? Hard to say, since no one entity is monitoring all of them. The NCAA recently contracted with a company to create a voluntary registry for agents, service providers and deals over $600, which may yield better information about the estimated $1.2 billion flowing through NIL collectives. On the nonprofit side, however, last June, the IRS issued a memo stating that the activities of many NIL nonprofits were not tax-exempt. In essence, the agency wrote that NIL deals serve the private interests of players, but not the public good. Phil Hackney, associate professor at the University of Pittsburgh’s law school, said the IRS offers tax-exempt status for organizations that probably should not qualify “happens more often than we might think." “There’s probably a lot of nonprofits that nobody’s focusing on that probably ought not have an exemption, but they do,” said Hackney, who formerly worked in the IRS’ Office of Chief Counsel. IRS spokesperson Anthony Burke said in May that the agency has a compliance strategy to make sure NIL nonprofits are “in full compliance with the existing legal requirements,” but did not elaborate. Since January, the IRS has released three rulings denying tax-exempt status for specific, but unnamed, organizations offering NIL contracts with college players. Some nonprofit NIL collectives continue to operate, though others have closed. The Texas One Fund that supports the Texas Longhorns still promotes its tax-exempt status on its website and hosted a fundraising concert in the football stadium in May. It did not respond to a request for comment. Athletes at the University of Utah last year received leases to new cars, in one of the highest profile NIL deals. The Crimson Collective, which is the school's official NIL, is registered as a nonprofit in Utah and has successfully applied for tax-exempt status from the IRS. Its most recent tax filing from 2022 indicates that it reported having less than $50,000 in revenue. Erin Trenbeath-Murray, vice president of philanthropy for Ken Garff Enterprises and the Crimson Collective, said the organization was not involved in facilitating the leases and that its purpose is to support other charities in the state, like Make A Wish Foundation, Huntsman Cancer Institute, Junior Achievement and other nonprofits. The Cohesion Foundation, which supports Ohio State athletes, said it stopped collecting new donations after the IRS memo, but paid out its contracts through the end of last year. Executive director Dan Apple said the collective is currently “inactive” but hasn’t taken down its website or publicly announced its closure in case something changes again. These nonprofits continue, in part, because large donors like to give through charitable vehicles so that they can take a tax deduction. “Where the big dollars come in and I’m talking six figures,” said Tom Dieters, president of the nonprofit organization Charitable Gift America, “Those come from grants. From donor-advised funds. Private foundations. Charitable trusts. We’ve even got a charitable IRA rollover money. You can only get those gifts as a public charity.” Dieters said his organization helps donors enter into NIL contracts with players at 10 schools around the country, including his alma mater, Michigan State. In return, athletes promote Charitable Gift America — through social media posts, for example. “We’re not unlike a car dealership that would promote their cars,” Dieters said. “We just promote philanthropy.” Brian Mittendorf, the H.P. Wolfe Chair in accounting at Ohio State, said he sees some window where it could be possible for a tax-exempt organization to enter into NIL contracts, but it would be a tricky line to draw. A nonprofit that existed before it started offering NIL contracts still must ensure its work furthers its charitable mission, he said. “(Organizations should) be able to demonstrate that the contracts they enter into are in furtherance of that charitable purpose and not to benefit any individuals in particular,” Mittendorf said. In the upcoming school year, the waters remain uncharted following a $2.8 billion settlement reached between the NCAA and the nation’s five biggest conferences that could create a revenue-sharing model with their athletes. At least one school, Houston Christian, has objected in court to the settlement arguing that it will divert money to sports from schools' core missions of education and research. Elsewhere, Virginia recently passed a law allowing schools to make NIL deals with players. Other states are wrestling with whether players can unionize. Hackney sees momentum for schools directly paying players somehow, though he argues that will further challenge whether the schools primarily serve a charitable education mission. “The system that allows this major business, major TV athletic product business, to operate as a charitable activity has long been problematic,” he said, in part because until recently, the athletes doing the work have not been paid. “Getting dollars to athletes for the real work that they do is important,” Hackney said. “But once you’re starting to pay them, you’re no longer operating a charity where you’re honestly there to educate these athletes. You’re there to pay them for a transactional business that’s not charitable anymore.”
  3. A big thing about NIL that people don’t realize is that our NIL collective donations are tax deductible for IRS purposes. This is a HUGE advantage when it comes to collecting NIL money that other big schools like Michigan don’t have. Our NIL collective was one of the first to get its tax deductible status before the IRS stopped allowing this to be done by all schools. I would like to see a comprehensive list of which schools have NIL collective tax exempt status because I think it makes a huge difference in how much money can be raised by a school.
  4. Elon is Adrian. He posted a screenshot on 4chan of Elon’s Twitter account and forgot that it shows his admin privileges and engagements that can only be seen by the account holder which is Elon.
  5. Notre Dame is much better than we are at converting red zone trips into touchdowns, so technically they wouldn’t have to rely on their kicker as much as we do.
  6. That ball just dropped into the breadbasket in stride
  7. The red zone struggles were not really an issue in 2021 with Casey and Hudson. Even though we went 5-7, we were #4 in the country at converting RZ drives into TDs at 74.47%. In 2022 when Quinn and Hudson took over, the RZ TD conversion rate dropped to 62.07% putting us at #65 in the country. This drop from #4 to #65 came even though we were averaging more RZ rushing YPC than in 2021 (and still had Bijan and Rojo in the backfield). In 2023 the RZ TD conversion rate was worse at 50.82%, #120 in the country. This year in 2024 (prior to yesterday’s game) the RZ TD conversion rate is actually better at 65.63%, #48 in the country (prior to yesterday’s game). So why the drop from 2021 onwards? Is it Quinn? Is it Sark? Is it Sark’s play calling for Quinn? Is it changes in the rushing game that negatively impact Sark’s playcalling? Our offense has been pretty consistent at staying around 34-35 ppg throughout the entirety of Sark’s tenure. The defense has shown significant improvement with opponent ppg decreasing yearly from 31.08 (2021), 21.62 (2022), 18.93 (2023), 14.47 (2024).
  8. Sark doesn’t have the situational awareness a HC needs to properly manage the clock and make the correct play calls. This is definitely holding Quinn and the offense back. Sark needs a flight simulator in the form of playing Madden. It doesn’t even have to be the fancy console Madden, it can just be Madden mobile which is basic as fuck. Sark brain farts in the circumstances where we can all see it coming.
  9. The success with the deep ball in 2023 masked the fact that we were actually worse in the red zone last year despite having better personnel and a better run game.
  10. Quinn was fucking money at the end. He set the house on fire with that late interception but let his nuts hang like a boss while putting out the flames.
  11. It sounds like Sark reads Surly and wants Mack to shut the fuck up about NIL. Here are his quotes: ”Adapting to what college football is now and not sitting around and complaining about it.” ”A lot of other coaches complain about what college football is all about right now and I think the two of us have been on the forefront of ‘here’s the rules, let’s maximize the opportunities we have to enhance our roster and our level of play.’”
  12. No steel/concrete barriers on NYE after this shit happened at Mardi Gras in 2017 and after that recent market attack in Germany that killed 5 people. What the fuck?!?
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