Chapman Law Review

Stars on the Field, Benchwarmers on the Tax Return: Student-Athletes and the Tax Ramifications of Name, Image, and Likeness Deals


"Ben has trained his whole life for this moment. The January sun is glaring down on the Indianapolis football field for the 2023 College Football Playoff National Championship. There are 24 seconds left on the clock, and Ben’s team is five points behind. They have worked so hard to get to this point in the season, and they cannot give it up now. The center snaps the ball to Ben, ho drops back into the pocket while surveying the field, frantically searching for an open receiver. Everyone is covered, so he is forced to roll out of the pocket and make the play with his legs. As he nears the line of scrimmage, a wide receiver breaks away from the defensive back. With no time to think, Ben lays the ball out deep down the field. Miraculously, the wide receiver hauls in the pass, scoring the game-winning touchdown with only 6 seconds left on the clock. Ben simply cannot believe it; all his dreams are coming true! He and his teammates are National Champions! The crowd is roaring, the team is ecstatic, and Ben is having the best day of his life!"

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