Analyzing the Applicability of IRC § 162 on the Pay-for-Play Model
16 VA. SPORTS & ENT. L. J. 2 (2017)).
26 Pages Posted: 28 Feb 2017 Last revised: 15 May 2018
Date Written: February 1, 2017
Abstract
Identifying the federal tax home of professional athletes has been a minimally examined area in academic scholarly works, but an important analysis for IRC § 162 business expense deduction purposes. However, due to the inconsistency among circuits in defining the term home from an IRC § 162 perspective, and because the U.S. Supreme Court has decidedly not clarified the definition of the term home for business expense deduction purposes, applying the conflicting interpretations could eventually pose an interesting federal tax issue for paid student-athletes. This article analyzes the realistic application of IRC § 162 on paid student-athletes, and proposes that interpreting the location of their federal tax home will require judicial guidance should the pay-for-play model be effectuated in the future.
Keywords: Pay-for-play, paid student-athletes, tax, federal tax home, IRC § 162, professional athletes, business expense deduction
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