The NCAA and the IRS: Life at the Intersection of College Sports and the Federal Income Tax

Few organizational acronyms are more familiar to Americans than those of the National Collegiate Athletic Association (NCAA) and the Internal Revenue Service (IRS). Although neither organization is particularly popular, both loom large in American life and popular culture. Because there is a tax aspect to just about everything, it should come as no surprise that the domains of the NCAA and the IRS overlap in a number of ways. For many decades, the strong tendency in those areas has been for college athletics to enjoy unreasonably generous tax treatment-sometimes because of the failure of the IRS to enforce the tax laws enacted by Congress, sometimes because Congress itself has conferred dubious tax benefits on college sports. In just the past year, however, there have been signs of what may be a major attitudinal shift on the part of Congress-although so far there have been no signs of a corresponding change at the IRS. This article offers an in-depth look at the history and current status of four areas of intersection between the federal tax laws and college sports. Part I considers the possible application of the tax on unrelated business income (UBI) to big-time college sports. It concludes that, even in the absence of any change in the statute, there is a strong argument that revenues from the televising of college sports should be subject to the UBI tax. Part II examines the tax status of athletic scholarships. It explains that athletic scholarships as currently structured are taxable under the terms of the Internal Revenue Code, and that the IRS seems to have made a conscious decision not to enforce the law. While the first two parts of the article address areas where the traditional sweetheart arrangement between the IRS and the NCAA remains in effect, the final two parts of the article consider areas where Congress has very recently intervened to increase the tax burden on college athletics. Part III describes how Congress, three decades ago, explicitly permitted taxpayers to claim charitable deductions for most of the cost of season tickets to college football and basketball games, and how Congress in 2017 to the surprise of many observers, including the authors of this article-repealed that special tax benefit. Finally, Part IV addresses issues of both statutory interpretation and policy raised by Congress\u27s creation, in 2017, of a 21 percent excise tax on at least some universities paying seven-figure salaries to their football and basketball coaches. The article\u27s conclusion suggests the IRS should follow the lead of Congress, and reconsider the administrative favoritism toward college sports described in Parts I and II

Contrasting the beam interaction characteristics of selected lasers with a partially stabilised zirconia (PSZ) bio-ceramic

Differences in the beam interaction characteristics of a CO2 laser, a Nd:YAG laser, a high power diode laser (HPDL) and an excimer laser with a partially stabilised zirconia (PSZ) bio-ceramic have been studied. A derivative of Beer-Lambert’s law was applied and the laser beam absorption lengths of the four lasers were calculated as 33.55 x 10-3 cm for the CO2 laser, 18.22 x 10-3 cm for the Nd:YAG laser, 17.17 x 10-3 cm for the HPDL and 8.41 x 10-6 cm for the excimer laser. It was determined graphically that the fluence threshold values at which significant material removal was effected by the CO2 laser, the Nd:YAG laser, the HPDL and the excimer laser were 52 J/cm2, 97 J/cm2, 115 J/cm2 and 0.48 J/cm2 respectively. The thermal loading value for the CO2 laser, the Nd:YAG laser, the HPDL and the excimer laser were calculated as being 1.55 kJ/cm3, 5.32 kJ/cm3, 6.69 kJ/cm3 and 57.04 kJ/cm3 respectively

Reheating predictions in single field inflation

Reheating is a transition era after the end of inflation, during which the inflaton is converted into the particles that populate the Universe at later times. No direct cosmological observables are normally traceable to this period of reheating. Indirect bounds can however be derived. One possibility is to consider cosmological evolution for observable CMB scales from the time of Hubble crossing to the present time. Depending upon the model, the duration and final temperature after reheating, as well as its equation of state, may be directly linked to inflationary observables. For single-field inflationary models, if we approximate reheating by a constant equation of state, one can derive relations between the reheating duration (or final temperature), its equation of state parameter, and the scalar power spectrum amplitude and spectral index. While this is a simple approximation, by restricting the equation of state to lie within a broad physically allowed range, one can in turn bracket an allowed range of $n_s$ and $r$ for these models. The added constraints can help break degeneracies between inflation models that otherwise overlap in their predictions for $n_s$ and $r$.Comment: 32 pages, 15 figures. Revised in response to comments on the original version, and in preparation for submission for publication. More references and a new figure were adde

Economic Analysis of High Fertilizer Input, Over-seeded Clover and Native Pasture Production Systems in the Texas Coastal Bend

This paper examined the cost and risk of three grazing systems to provide information on economically sustainable systems for cattle producers in the Texas Coastal Bend. Results indicate the medium input (over-seeded clover) grazing system displays first degree stochastic dominance relative to the high input and no input grazing systems.grazing system economics, forage production economics, Crop Production/Industries, Livestock Production/Industries, Production Economics,

Application of CFD to sonic boom near and mid flow-field prediction

A 3-D parabolized Navier-Stokes (PNS) code was used to calculate the supersonic overpressures from three different geometries at near- and mid-flow fields. Wind tunnel data is used for code validation. Comparison of the computed results with different grid refinements is shown. It is observed that a large number of grid points is needed to resolve the tail shock/expansion fan interaction. Therefore, an adaptive grid approach is employed to calculate the flow field. The agreement between the numerical results and the wind tunnel data confirms that computational fluid dynamics can be applied to the problem of sonic boom prediction

Using Full Information When Computing Modes of Post-Newtonian Waveforms From Inspiralling Compact Binaries in Circular Orbit

The increasing sophistication and accuracy of numerical simulations of compact binaries (especially binary black holes) presents the opportunity to test the regime in which post-Newtonian (PN) predictions for the emitted gravitational waves are accurate. In order to confront numerical results with those of post-Newtonian theory, it is convenient to compare multipolar decompositions of the two waveforms. It is pointed out here that the individual modes can be computed to higher post-Newtonian order by examining the radiative multipole moments of the system, rather than by decomposing the 2.5PN polarization waveforms. In particular, the dominant (l = 2, m = 2) mode can be computed to 3PN order. Individual modes are computed to as high a post-Newtonian order as possible given previous post-Newtonian results.Comment: 15 page

Two energy scales and slow crossover in YbAl3

Experimental results for the susceptibility, specific heat, 4f occupation number, Hall effect and magnetoresistance for single crystals of YbAl$_{3}$ show that, in addition to the Kondo energy scale $k_{B}T_{K}$ $$ 670K, there is a low temperature scale $T_{coh}<50$K for the onset of coherence. Furthermore the crossover from the low temperature Fermi liquid regime to the high temperature local moment regime is slower than predicted by the Anderson impurity model. These effects may reflect the behavior of the Anderson Lattice in the limit of low conduction electron density.Comment: Ten pages, including three figure

Black and minority ethnic trainees’ experiences of physical education initial teacher training

The official published version can be accessed at the link below.This report draws together the findings of research that aimed to explore black and minority ethnic (BME) trainees’ experiences of Physical Education (PE) initial teacher training (ITT). Although the numbers of BME trainees opting to enter teaching have improved considerably over the last few years, PE remains one of three specific subject areas where they remain significantly under-represented. Current figures suggest that PE attracts approximately 3% of trainees from BME backgrounds, compared with 11% for new entrants into teaching overall. The relative lack of success in attracting BME trainees into PE teaching compared to other subject areas suggests that the subculture of the subject may be a compounding factor. Over the last decade or so, a number of studies have explored the impact of ethnicity on teachers’ professional socialisation and their experiences as teachers in school, but none have focused on experiences within specific subject cultures. The centrality of the body in PE, and the link between this and the perceived low status of the subject, are influencing factors highlighted in the broader literature, including sports studies. For example, research exploring racism and the under-representation of BME participants in sport has highlighted the prevalence of stereotypical attitudes about their physicality and abilities held by coaches, administrators and spectators. Other research has suggested that some minority ethnic groups favour higher status, better paid, careers in areas such as law or medicine rather than teaching. As yet, there has been little attention to ‘race’ and ethnicity within PEITT, although studies have shown the impact of gender on trainees’ developing professional identities, and how teachers’ gendered bodies are important ‘tools’ of their work. In addition, there has been little research that has acknowledged trainees’ multiple identities, or the complex ways in which ‘race’, ethnicity, class and gender and other identity markers intersect to impact on the professional socialisation process. The research on which this report is based sought to fill some of these gaps in our understandings of BME trainees’ experiences of PEITT, and to identify strategies that might help in their recruitment and retention in the longer term. The research was funded through a small Recruitment and Retention Challenge Grant from the Teacher Development Agency (TDA). These grants form part of the TDA’s wider policy agenda to widen the diversity of new intakes opting into teaching. Higher education institutions have been encouraged, through targets and financial support and incentives, to develop specific strategies aimed at widening the diversity of their cohorts. Examples of such strategies include the provision of specialist admission help for BME prospective trainees; opportunities to gain experience in schools; open days and ‘taster’ events; advertising in the ethnic minority media, and the development of good practice guides and staff training to help ITT providers address issues of ‘race’ and ethnicity. 5 The impetus for this research resulted, in part, from presentations and discussions at a one day PEITT Network1 staff seminar on diversity held in October, 2007. The quantitative research conducted by the Association for Physical Education (AfPE) and the Ethnic Minority Foundation (EMF) presented here, showed the extent of the national under-representation of BME students in PEITT. Although the day focused on addressing reasons for BME under representation and strategies that might be used for improving recruitment, we felt it was also important to learn about the qualitative experiences of trainees that have been attracted into PEITT. Understanding the experiences of our current BME trainees might offer useful insights into how we might recruit and retain future such trainees. Our choice of qualitative research was supported by a national study published shortly after the network day, investigating the links between gender, ethnicity and degree attainment (Higher Education Academy, HEA, 2008), which specifically calls for further qualitative studies of students’ experiences of different subject areas.Funding from the Training and Development Agency (TDA

Measuring the Fraction of Obscured Quasars by the Infrared Luminosity of Unobscured Quasars

Recent work has suggested that the fraction of obscured AGN declines with increasing luminosity, but it has been difficult to quantify this trend. Here, we attempt to measure this fraction as a function of luminosity by studying the ratio of mid-infrared to intrinsic nuclear bolometric luminosity in unobscured AGN. Because the mid-infrared is created by dust reprocessing of shorter wavelength nuclear light, this ratio is a diagnostic of f_obsc, the fraction of solid angle around the nucleus covered by obscuring matter. In order to eliminate possible redshift-dependences while also achieving a large dynamic range in luminosity, we have collected archival 24 micron MIPS photometry from objects with z~1 in the Sloan Digital Sky Survey (SDSS), the Great Observatories Origins Deep Survey (GOODS) and the Cosmic Evolution Survey (COSMOS). To measure the bolometric luminosity for each object, we used archival optical data supplemented by GALEX data. We find that the mean ratio of 24 microns to bolometric luminosity decreases by a factor of ~3 in the L_bol=10^44-3x10^47 ergs s^-1 range, but there is also a large scatter at constant L_bol. Using radiation transfer solutions for model geometries, we show how the IR/bolometric ratio relates to f_obsc and compare these values with those obtained obtained from samples of X-ray selected AGN. Although we find approximate agreement, our method indicates somewhat higher values of f_obsc, particularly in the middle range of luminosities, suggesting that there may be a significant number of heavily obscured AGN missed by X-ray surveys.Comment: ApJ, in press. 10 pages in emulateapj style, 4 figures, 3 table