ANALYZING THE EFFECT OF THE SEATING-RIGHT TAX
DEDUCTION ON ATHLETIC DEPARTMENTS IN THE PAC-12
By:
SEAN KILLPATRICK
A THESIS
Presented to the Department of Accounting
and the Robert D. Clark Honors College 
in partial fulfillment of the requirements for the degree of 
Bachelor of Science
 June 2020
An Abstract of the Thesis of
Sean Killpatrick for the degree of Bachelor of Science
in the Department of Accounting to be taken June 2020
Title: Analyzing the Effects of The Elimination of The Seating-Right Tax Deduction on
Athletic Departments in The Pac-12
Approved: ________Angela Davis, Ph.D.___________
Primary Thesis Advisor
In 2017, President Donald J. Trump signed the Tax Cuts and Jobs Acts (TCJA), 
making the changes effective for the 2018 tax year. This Act eliminated The Seating-
Right Tax deduction which allowed donors to deduct 80% of their donation toward 
securing the right to purchase season tickets for any Pac-12 team. The research below 
aims to analyze if this implementation would have any effect on the University of 
Oregon Athletic Department, Pac-12 Athletic Departments, or showcase change in 
donor behavior. The primary focus being whether this tax change had a negative impact
on athletic departments, more specifically the revenue generating sports, football and 
men's basketball teams. By directly contacting all Pac-12 Athletic Departments via 
email, their seating contribution revenue for men’s football and basketball from their 
2017-2019 seasons were obtained. During this time various interviews took place 
allowing the opportunity to gauge athletic department’s reactions to this tax change. 
Once that information was collected the next step was to interview donors about their 
donating habits and gather their response to the new changes. Overall, there has been a 
decrease in seating contributions, but the data showed that this decline was not directly 
correlated to the eliminated deduction. In fact, the elimination of the Seating-Right Tax 
ii
deduction did not affect a donor's willingness to donate at all. Based on the information 
collected it can be concluded that donors are not making these contributions solely for 
the tax benefits, but for the benefit of the program and the opportunity to enjoy 
collegiate athletics.
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Acknowledgements
I would like to thank Angela Davis, for helping me on my journey with my 
thesis and being my primary thesis advisor throughout the process of making my thesis. 
It was enriching to discuss this tax change and see how I could relate it to football and 
accounting. I would also like to thank Dr. Barbara Mossberg and Eric Roedl for being a 
part of my thesis committee and sharing their expertise with me. I am incredibly 
grateful to work with these individuals and so thankful for their support throughout this 
process.
I would also like to thank God and my parents, Michael and Vonnesia 
Killpatrick, for providing me with the path to come to University of Oregon and the 
ability to have great collegiate experience with endless support. Special Thanks to 
Devin, Isabella, Alisha and friends for keeping me motivated and supportive during this
thesis process. Without everyone involved I would not be where I am today, so thank 
you!
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Table of Contents
Introduction 1
Background 2
Standard Deduction (Prior to 2018) 2
Itemized Deduction (Prior to 2018) 3
Charitable Contribution - Tax Incentive 5
Effects on the Athletic Department (Duck Athletic Fund) 6
Review of the Literature 8
Tax Cuts and Jobs Acts 8
Changes to the Itemized Deduction 10
Elimination of the Seating-Right Tax Deduction 12
Research Question 14
Research Methods and Limitations 15
Initial Findings 15
Data Collection and Interview Insight 16
Limitations 17
Results 19
Pac-12 Football Data Collection and Analysis 19
Pac-12 Men’s Basketball Data Collection and Analysis 20
Pac-12 Universities Tax Change Survey Questions 21
Discussion 24
Pac-12 Seating Contribution Tables Discussion 24
Pac-12 Survey Discussion 24
Donor interviews- Anecdotal Evidence 25
Conclusion 28
Bibliography 30
v
List of Tables 
Table 1:2017 Standard Deduction 2
Table 2: 2017 Itemized Deductions 4
Table 3: The Pease Limitation Thresholds 5
Table 4: Changes to the Standard Deductions 9
Table 5: Changes to Itemized Deductions 11
Table 6: Pac-12 Football Seating Contribution 19
Table 7: Pac-12 Men’s Basketball Seating Contribution 20
Table 8: Pac-12 Survey Question #1 22
Table 9: Pac-12 Survey Question #2 23
Table 10: Pac-12 Survey Question #3 23
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Introduction
Athletic Departments have a long tradition of relying heavily on the contribution
of donors. Donations and gifts are one of the main sources of revenue for athletic 
programs and provide funding for all student athletes. "These donations help support 
capital campaigns such as stadium renovations, student-athlete scholarships, sports 
program operating costs, and academic support services.'' (Howard, 2018) Without the 
generous donations of donors, athletic departments would not be what they are today, 
and many smaller school departments would not survive without them. My thesis looks 
at the Seating-Right Tax deduction that was enacted in 2017, and the potential affect it 
might have on donations in the following years. I begin by discussing the background 
on the tax laws before the tax change went into effect and how the University of Oregon
Athletic Department prepared for this transition. Next, I go more in depth about the 
changes that occur after the passing of the Tax Cuts and Job Acts and how the different 
Pac-12 athletic departments responded. Concurrently, I collected seating donation data 
and responses from eight Pac-12 athletic departments about their seating donation 
revenue. Finally, I assessed whether or not the tax change had any impact on overall 
seating donations and compared the data to my predictions.
Background
Standard Deduction (Prior to 2018) 
Tax deductions allow individuals to subtract certain qualifying expenses from 
their taxable income, reducing their overall tax bill. The Internal Revenue Service (IRS)
created the standard deduction in 1944 as a way to simplify the tax system. Taxpayers 
can elect to either take the standard deduction and avoid having to track their qualifying
expenses throughout the year or deduct the total of all qualifying expenses they incurred
during the year which is referred to as “itemizing deductions.” If a taxpayer's qualifying
expenses exceed the standard deduction allowed in a year, then they would elect to 
itemize deductions on their tax return. The standard deduction amounts change each 
year and depend on a taxpayer's filing status. The filing status consists of 5 different 
categories as demonstrated below for the 2017 tax year.
2017 Standard Deductions
Filing Status 2017 Tax Year
Single (Unmarried) $6,300
Head of Household $9,300
Married Filing a Joint Return $12,600
Surviving Spouse (Qualifying Widow or $12,600
Widower) 
Married Filing a Separate Return $6,300
Table 1:2017 Standard Deduction 
There are additional amounts that can be added to a taxpayer's standard 
deduction if they meet certain criteria. Taxpayers who are 65 years of age and older at 
2
the end of the tax year or who are blind, are allowed an additional standard deduction of
$1,550 if they file as single or head of household. If an individual meets both criteria, 
they qualify for a deduction of up to $3,100. Additionally, if a person files as married, 
surviving spouse, or married filing a separate return and meets one or both criteria, then 
they qualify for a deduction of $1,250. If both parties filing as married meet both 
requirements, then their deduction can total up to $2,500. There is no additional 
standard deduction allowed for dependents who are blind and/or 65.
Itemized Deduction (Prior to 2018)
Itemized deduction is the sum of all qualifying expenses that is subtracted from 
an individual's income to determine their taxable income, also known as adjusted gross 
income (AGI). A taxpayer can elect to itemize deductions instead of taking the standard
deduction. The table below lists the categories of itemized deductions allowed in 2017 
before the implementation of the Tax Cuts and Jobs Act.
2017 Itemized Deductions 
 Itemized Deductions Limitation Type Limit Described
Medical Expense Floor 10% of AGI under age 65 and
7.5% for over
Taxes No limit 
You elect to deduct state or local
general sales taxes you paid in a
tax year
Home Acquisition Ceiling Interest up to $1,000,000 of debt
principal unless filing married
then the limit is $500,000
Investment Interest Ceiling Interest up to the amount of the
net investment income
3
Cash Charitable Contribution Ceiling 50% of AGI
Charitable Contributions of Ceiling 30% of AGI
long-term capital gain
property
Casualty and Theft Losses Floor 10% of AGI
Miscellaneous Itemized Floor Exceed 2% of AGI
Deductions
Table 2: 2017 Itemized Deductions
Itemized deductions are limited by a floor or ceiling depending on the 
deduction. Deductions that have a floor or minimum must exceed the taxpayer’s AGI 
before the excess can be included in as an itemized deduction. Deductions with a 
ceiling, such as charitable contributions, are limited based on various percentages of 
adjusted gross income. Before 2018, "about 30% of taxpayers have itemized deductions 
(on Schedule A) because their total itemized deductions were more than the standard 
deduction based on their filing status.”(Pickering, 2020) Taxpayers can maximize the 
use of their standard deduction or itemized deduction by using the highest of the two in 
one year and the other the next year. 
Prior to 2018, taxpayers with a certain income were subjected to an itemized 
deduction phase-out or limit called, The Pease Limitation. The Pease Limitation was 
used to put a cap on how much taxpayers could claim as itemized deductions if their 
income was over a certain threshold. This particular phase-out does not apply to all 
itemized deductions, specific categories such as medical expense, investment expense, 
theft and casualty losses were excluded, while home mortgage interest, state and local 
taxes, charitable contributions, and certain miscellaneous deductions became limited for
wealthier taxpayers. The limit was based on filing status before 2018. 
4
When a taxpayer's AGI exceeds the stated limits, their total itemized deduction 
is reduced by 3% of AGI above the applicable threshold. Also, if the taxpayer is a 
wealthier individual whose AGI surpasses the thresholds, their itemized deduction is 
capped at 80% of their AGI (the balance). The table below shows the limits for 2017.
Filing Status AGI Limit for 2017
Single $261,500
Married filing joint $313,800
Married filing separate $287,650
Head of household $156,900
Table 3: The Pease Limitation Thresholds
Charitable Contribution - Tax Incentive
Section 170 of the U.S. Tax Code discusses charitable contributions, which is 
one example of an itemized deduction. According to Section 170, taxpayers are allowed
to deduct gifts made to qualified charitable organizations up to a regulated amount. 
Only a gift with a value of $250 or more is a qualifying expense. In addition to being 
eligible for receiving a gift, one would need a statement from the charitable 
organization outlining the contribution made even if the organization gave the taxpayer 
any goods or service in return. If a taxpayer receives a good or service in return for a 
contribution, only the portion of the gift in excess of the fair value of the good or 
service received is deductible. For example, if a taxpayer is at dinner and makes a $100 
donation and receives a $25 meal, then the taxpayer can deduct $75 as a charitable 
contribution for tax purposes. 
5
Charitable contributions increase a taxpayer’s itemized deductions, allowing 
them to choose whether to take the standard deduction or to itemize deductions 
depending on the total amount of their qualifying expenses relative to the standard 
deduction allowed in a given tax year. Section 170 allows for an additional incentive for
donors to contribute to athletic programs because Universities are classified as qualified
charitable organizations. 
Effects on the Athletic Department (Duck Athletic Fund)
The Oregon Duck Athletic Fund (DAF) is the primary source of funding for the 
University of Oregon Athletic Department. Over the years, the DAF has fundraised to 
compensate for expenses throughout athletics, but also to fund scholarships. The DAF 
raises over $12 million annually for student-athlete scholarships. These funds support 
more than 450 athletes across all Oregon varsity sports. Back in 2017, the Oregon Duck
Athletic Fund had a total of 7,510 donors. They estimate about 80% of their donor 
population are transactional donors, meaning they donate money for various reasons, 
including, but not limited to securing the right to purchase season tickets that will result 
in tax benefit. The other 20% of donors are philanthropic donors who support charities 
of meaning and value. A review of the Athletic Department’s budget at the University 
of Oregon indicates that $27 million (22%) of the department’s $123 million fiscal year 
2020 athletic budget is funded by gifts and donations. As the expenses for athletic 
operation cost increases, donations play a pivotal role in covering those costs.
Former Associate Director of Development at the University of Oregon Athletic 
Department, James Batley, was not expecting the elimination of the Seating-Right Tax 
deduction. The department did not anticipate the change, nor did they believe that it 
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would have an impact on only non-profits, but that it would directly impact athletic 
departments in the NCAA. With the elimination of the deduction, the DAF looked to 
other nonprofit organizations and athletic departments to see what changes were being 
made to compensate for the potential loss while staying in compliance. Before the end 
of 2017, the University of Oregon made their donors aware of the changes coming in 
2018 and allowed prepayments of donations/gifts to the Oregon Athletic Department for
the coming year. Without having much knowledge of the new tax reform and how it 
would affect donations, they ultimately tried to predict what quick changes needed to be
made before the end of the year to capitalize on donations. Between their transparency 
of what their intentions were and the ability to contact donors quickly the DAF brought 
in $10 million in the month of December 2017 alone.
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Review of the Literature
Tax Cuts and Jobs Acts
On December 22, 2017, President Donald J. Trump signed the Tax Cuts and 
Jobs Acts (TCJA), an overhaul of legislation changing the tax landscape from 2018 to 
2025. Its purpose was to stimulate the economy in both short and long term. However, 
in the long run, a smaller increase in Gross Domestic Product (GDP) and Gross 
National Product (GNP) is expected to occur. (Gale, 2018) The new law would reduce 
federal revenue significantly while allowing economic growth. This could take away 
from government agencies that rely on the taxpayers dollars. The Act also decreases 
funding to agencies that fight against money laundering and fraud, which is vital for 
keeping large and small businesses accountable for their financials. In some ways, the 
simplified taxes will increase complexity for health care programs by raising premiums 
along with reducing health insurance coverage. It will also affect state and local public 
spending, charitable organizations, and housing. It is estimated that the TCJA will 
increase the national deficit by $1.8 trillion through 2028 imposing future damages on 
future generations. Through this Act, Congress placed limits on itemized deductions 
causing a reduction in the number of taxpayers who can benefit from this option. It also 
significantly increased the standard deduction, creating incentives for taxpayers to 
choose the standard deduction over itemizing expenses. 
Changes to the Standard Deduction
The Tax Cut and Jobs Act has significantly increased the standard deduction by 
doubling the amount of each of the filing status. The amounts were indexed annually 
8
due to inflation. The increase in standard deduction created incentives for taxpayers to 
pick the standard deduction over the itemized deduction since they would need to have 
enough qualifying itemized expenses to surpass their filing status deduction. As a result,
the number of taxpayers choosing to itemize their deductions decreased significantly 
following the TCJA. (Gale, 2018) The table below shows the change in the standard 
deduction for the 2017, 2018 and 2019 tax years.
Filing Status 2017 Tax Year 2018 Tax Year 2019 Tax
Year
Single (Unmarried) $6,300 $12,000 $12,200
Head of Household $9,300 $18,000 $18,350
Married Filing a Joint $12,600 $24,000 $24,400
Return
Surviving Spouse $12,600 $24,000 $24,400
(Qualifying Widow or
Widower) 
Married Filing a $6,300 $12,000 $12,200
Separate Return
Table 4: Changes to the Standard Deductions
Not only did the standard deductions for filing status change due to the passing 
of tax cuts, but the amounts changed for taxpayers who classify as being at least 65 
years old or blind. Those who meet at least one of the criteria and filing as single or as 
heads of household had their additional standard deductions increased to $1,600 and 
those who meet both criteria saw an increase to $3,200. Taxpayers filing as married, 
surviving spouses and married filing a separate return who meet at least one of the 
criteria saw an increase to $1,300 and up $5,200 if the couple both met each criteria. 
There is still no additional standard deduction allowed for dependents who are blind 
9
and/or 65. Taxpayers can maximize the use of their standard deduction or itemized 
deduction by using the higher of the two for one year and selecting the other for the 
next year.
Changes to the Itemized Deduction
Beginning in 2018, the new TCJA bill went into effect causing drastic changes 
to itemized deductions. This Act created additional limitations and eliminations, making
itemized deductions less accessible to taxpayers. As a result of the tax change, tax 
benefits dropped affecting the three major itemized deductions such as, state and local 
taxes, mortgage interest, and charitable contributions from 2017 to 2018. (Gale, 2018) It
is estimated that the share of all households that itemized will shrink to 10% due to the 
tax overhaul. (Gale, 2018) The changes that occur to qualifying itemized deductions are
located on the chart below. These restrictions for itemized deductions will last from 
2018 to 2025 before any changes are allowed to be made.
Itemized Deductions After 2018
Deductions Limitation Type Limit Described
Medical Expense Floor 7.5% of AGI
Taxes Ceiling 10,000
Home Acquisition Ceiling Interest on up to
750,000 of debt
principle
Investment Interest Ceiling Interest up to the
amount of net
investment income
10
Cash Charitable Ceiling 60% of AGI
Contribution
Charitable Contributions of Ceiling 30% of AGI
Long-Term Capital Gain
Property
Casualty Loss from Floor 10% of AGI
Federally Declared Disaster
Only
Miscellaneous Itemized No deduction
Deductions
Table 5: Changes to Itemized Deductions
Each itemized deduction was affected in different ways. The itemized 
deductions that were noticeably changed were Taxes, Home Acquisitions, Cash 
Charitable Contribution, Medical Expense, and Miscellaneous Itemized Deductions. For
taxes, taxpayers can still deduct state and local real estate, personal property, and either 
income or sales tax but the total State and Local Tax limitation is capped at $10,000. 
Under the Home Acquisition Deduction, the tax change limited the deduction on home 
mortgage interest on the first $750,000 of mortgage loans taken out after December 15, 
2017. Also, homeowners may no longer deduct interest paid on home equity loans 
unless the debt is used to build, purchase, and improve homes. Homeowners can still 
deduct mortgage interest on their primary or secondary home. A positive change occurs 
with the increase in the ceiling for Cash Charitable Contribution. The TCJA increased 
the limit for Cash Charitable Contribution deduction from 50% to 60% of adjusted 
gross income. The medical expenses floor was lowered to 7.5% of adjusted gross 
income from 10%. Under the Miscellaneous Itemized deductions section, TCJA 
eliminated deductions for unreimbursed employee expenses, tax preparation fees, and 
other miscellaneous deductions. It also eliminated the deduction for theft and personal 
11
casualty losses. On the upside, taxpayers can still claim a deduction for casualty losses 
due to federally declared disasters. (Gale, 2018) The TCJA also eliminated the Pease 
Limitation on itemized deductions as discussed in the previous section.
Elimination of the Seating-Right Tax Deduction
The tax cuts might have negative effects on collegiate athletic departments, 
primarily affecting schools within the Power 5 Conference, which the Pac-12 is a part 
of. Each institution inside of this conference is known to have high operating costs and 
revenue from their revenue-generating sports including football and basketball. When 
looking at the data provided, football single-handedly generates over $3 million per 
home game all of which is used to cover the cost of the event. I am exploring the 
elimination of the Seating-Right Tax deduction and how this tax change might impact 
revenue generation from ticket sales.
Prior to 2018, University of Oregon donors and fans were required to donate a 
certain amount of money to the athletic department to secure the right to purchase 
season tickets for certain seating locations at football and basketball games. The 
required donations increase with the quality of the seats. After the athletic department 
approves of the donation and sends a receipt back to the donor, the donor can deduct 
80% of the contribution on their taxes. As an example, to secure the seat rights to 
purchase box seats on the 50-yard line at the University of Oregon football game, 
alumni would need to donate $2,401 to secure the right to purchase preferred season 
tickets for all the home games. When filing taxes, the donor could deduct $1,920.8 
($2,401 x 80%) under their itemized deductions. This charitable contribution deduction 
12
would benefit taxpayers by increasing the total of their itemized deductions on their tax 
return.
13
Research Question
My thesis aims to analyze the effects, if any, of eliminating the Seating-Right 
Tax deduction on the University of Oregon Athletic Department, Pac-12 Athletic 
Departments, and any change in donor behavior. The following questions were used to 
gain more insight on this topic, “How has the University of Oregon’s Athletic 
Department been affected and how have future plans changed due to the tax change?” 
The answers obtained will support further investigation into the impact of this tax 
change within the Pac-12 Athletic Departments and any concerns and/or reactions 
regarding this change. 
My next question is, “Do athletic departments anticipate a decrease in Football 
and/or Men’s Basketball seating donations in either the short or long term? Will there 
be a change in attitude with donors and if so, will that change cause the number of 
donors along with annual donations to decrease?” The answers will reflect a possible 
trend in how donors are going to respond in regard to the tax change.
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Research Methods and Limitations
I began my research process by digging into the Tax Cuts, Job Act and the 
changes made to taxes as a whole. I then narrowed my focus to learning about the 
elimination of the Seating-Right Tax deduction and it became evident that a seemingly 
small tax change can have a big impact, specifically, on the revenue stream of various 
athletic departments. There is no conclusive evidence to why the Seating-Right Tax 
deduction was eliminated with the signing of this act. This elimination of this deduction
gave me the opportunity to explore the effects it may have on both accounting and 
sports. 
Initial Findings
At the beginning of 2019, I interviewed the DAF Assistant Athletic Director of 
Operations about the actions the Oregon Athletic Department took in response to the 
change and how the Pac-12 communicated this change. Below you will find a listing of 
each institution’s course of action or thoughts around the elimination of the Seating-
Right Tax deduction: 
The University of Oregon- No plans to make any changes to their donations 
structure such as their priority point system. The tax change was at the bottom of their 
list for reasons not to donate
University of Utah- Did not provide any information
Oregon State University- The tax change ranked 12 out of 15 on their survey 
for non-renewal reasons
15
University of California-Los Angeles- Their university’s foundation would not
give donation receipts for anything tied to seating contributions
Washington State University- Communication with donors needs to be 
focused around a philanthropic viewpoint rather than transactional
The University of Washington- The tax change ranked 13 out of 16 on their 
survey of non-renewal reasons
The University of Southern California- Changed from gift receipts to payment
acknowledgment 
The University of Colorado-Boulder- Their university’s foundation would not 
give donation receipts for anything tied to seating contributions
The University of California-Berkeley- Did not provide information
Arizona State University- Consulted with EY about tax reform
 Stanford University-  Their university’s foundation would not give donation 
receipts for anything tied to seating contributions
The University of Arizona- Were mainly concerned about the effect on football
donations rather than basketball
 Data Collection and Interview Insight
Before assessing any seat donation amounts, universities felt the elimination of 
the Seating-Right Tax deduction brought little concern to donors and was not the 
primary reason that donors are not making contributions. This insight led me to collect 
recent data from each institution in order to analyze their donations over the two years 
the tax change has been in effect.
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Second, I emailed each university about the donation revenue they saw from 
Football Seating/Parking Contributions, Football Sky Suite Contributions, and Men's 
Basketball Seating Contributions from 2015 to 2019. I wanted to be able to look at their
overall historical trend in donation revenue for this time frame to see if the elimination 
of the deduction beginning in the 2018 tax year had any affect. The fluctuation of 
revenue could be explained for an assortment of reasons, beginning with team success, 
player changes, coaching and administrative changes, donor involvement, and media 
spotlight. 
Next, using tables, I analyzed the amount of donation revenue before and after 
the tax change to see if any impact occurred during 2017-2019. Along with collecting 
donation amounts, I surveyed other Pac-12 departments on their donor count before and
after the tax change, and the amount of revenue collected in December of 2017 versus 
their usual December donations. Their response to the questions will be displayed in the
tables below. 
Lastly, I Interviewed Oregon donors to gain insight into their reason for 
donating and if the elimination of the Seating-Right Tax deduction affected their 
willingness to contribute. In conclusion, I will assess if the data I collected demonstrates
that the tax change had an overall impact on athletic departments within the Pac-12.
Limitations
Data limitations did occur while writing this thesis. One limitation was not being
able to get a response from every school in the Pac-12. Fortunately, enough to 8 of the 
12 institutions responded to my inquiries. Another limitation for data arose when I 
noticed that each school differs in how they account for donations whether it is based 
17
off of their fiscal-year, year-end year or calendar year. The University of Oregon's totals
were calendar year figures based on the year in which the sport's athletic seasons 
started. For example, the Football season 2017-2018 will count towards the total of 
2017. Therefore, donation totals could be higher in either 2017 or 2018 due to the 
collection of as many donations as possible to prepare for the tax change. Institutions 
also did not start tracking their total seat donations until 2014 so it is hard to notice if 
there is a decade long pattern for seat donations.
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Results
Pac-12 Football Data Collection and Analysis
Table 6: Pac-12 Football Seating Contribution
Looking at the data, every school in the 2017-2019 Football 
Seating/Contribution category was trending downwards except for the University of 
Washington, who saw an increase in their donations by $1.2 million over those two 
years. Washington’s intake of donations could be due to its 2018 seat reallocation 
discussed in the Pac-12 survey questions below. Through 2017 and 2019 Football Sky 
Suite Contribution was relatively upward trending during 2017 and 2018 compared to 
general football seating except for Stanford, Oregon State University, and the 
University of Arizona who saw a slight decrease. It was surprising to see 
donors/companies still holding on to their Sky Suites after 2017 since the donations are 
priced higher than regular season tickets but came with no additional tax benefit. I 
thought the figures would have trended downward similar to general season tickets with
2017 being the highest in donations, but this could be due to the influx of donations 
preparing for the tax changes. In 2019, all institutions saw a decrease in donations to 
Sky Suite Contributions which aligns with the Football Seating/Contribution’s 
19
trajectory. Overall, it is difficult to definitively conclude that the tax change caused a 
significant impact on donations for Football Seating/Contribution and Football Sky 
Suite Contribution but their totals are trending downward now and could fall further.
Pac-12 Men’s Basketball Data Collection and Analysis
Table 7: Pac-12 Men’s Basketball Seating Contribution
Looking at the 2017-2019 Men's Basketball Seating Contribution, there was no 
correlation between the different institution’s donation trends. As an outlier, the 
University of Arizona did exceptionally better than other Pac-12 schools in donations 
averaging over $10 million annually. Again, the University of Washington had an 
upward trend starting in 2017 along with the University of Oregon and Oregon State 
University. Other institutions were able to accumulate larger sums of donations in 2017 
but also experiencing a decrease over time in donations. Overall, their per-seat 
donations were similar to that of the football donations. Basketball per-seat donations 
could also expect to see a decrease over time. 
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Pac-12 Universities Tax Change Survey Questions
The survey questions below examine the responses from eight surveyed athletic 
departments and give an institution specific perspective on the Seating-Right Tax 
deduction. The first question asked, “Was there an influx in gifts the month before the 
tax change, December 2017, compared to previous months in order to analyze if the 
increase in donations was motivated by the tax change?” The next question was to 
assess if any particular department took any precautions prior to the tax change to 
reorganize their operational practices pertaining to seat contributions. Finally, a review 
donor participation to see if there were any trends that arose after the tax change.
1) Were you able to track an influx of gifts in the months of 
Pac-12 November/December 2017 due to the pending tax reform changes 
Universities and if so, what is the total amount? Also, what are your usual 
donations within those months?
Every 5 years our football and basketball season ticket holders go 
through a full seat reallocation. 2018 was a reallocation year for 
football which created a unique situation in which season ticket 
holders who did not know their seat-related gift until their seat 
selection in February and March. 
Due to the tax law change, we allowed season ticket holders to make a
non-refundable gift into a seat-related holding fund which was then 
University of applied to their 2018 seat-related gift after they selected their seats 
Washington during reallocation. Men's Basketball season ticket holders also made 
contributions to the holding fund which was then applied to their 
balance when they renewed their seats. This allowed season ticket 
holders to receive the tax benefit for their 2018 seat gifts for Football/
Men's Basketball.
We received $4.5 million to the holding fund from December 18th 
through December 31 after the news of the tax law was 
communicated.
University of 2016:   $5,873,523
Oregon 2017:   $8,472,4362018:   $3,366,541
Oregon State Yes, we allowed donors to make gifts in advance of the tax legislation.
University We provided donors the opportunity to pay their seat contributions 
21
three years in advance or through the 2020 football season.159 donors
elected to make their 2019 seat contribution in advance equaling 
$996,000. 81 donors elected to make their 2020 seat contribution in
advance equaling $340,000
University of N/A
California-
Berkeley
No, we did not see an influx of gifts in these months and did not 
Stanford communicate to donors to encourage giving before the calendar year-end. We received the typical amount of donations for calendar 
year-end in December that year, which is around $2 million.
At this point, we have not been negatively affected by the elimination 
of the tax deductions for seat donations. We have seen a decrease in 
University of season ticket sales over the last two years. We received roughly $3 
California-Los million in giving at the end of 2017. This included annual gifts that
Angeles people typically make but chose to donate before the tax law 
changed. This also included people who prorated their giving for 
multiple years.
University of Our average excluding 2017 over the last five years is $2.8 million in 
Arizona the months of November and December. In 2017, that total was $12.2 million or an additional $9.4 million than the other years.
Table 8: Pac-12 Survey Question #1
Pac-12 2) Since the tax change in 2018, has your school made any 
Universities changes to operational practices pertaining to per seat contribution, football suites, or priority point systems?
University of We have not made any changes to operational practices pertaining 
Washington to per seat contribution, football, suites, or priority point systems. 
An extensive review of our priority point system was done by outside 
tax advisors and an opinion statement was provided indicating that 
University of our priority point system did not need to change. Seating 
Oregon contributions are tracked separately now to provide proper tax receipts. Tax receipts and gift acknowledgment text has changed in 
order to reflect the current IRS rules and better educate donors of the 
change.
Oregon State Yes, we rolled out our new business practice.
University
Since the tax change in 2018, all per-seat donations have been 
made to our general fund. We use giving days such as Big Give and
University of Giving Tuesday to offer double priority points to those who donate 
California- (they can give to any sport). All per-seat donations must be in before 
Berkeley the start of the season or your tickets get held. We offer priority 
points for a large range of giving such as consecutive years of giving, 
how much you give, and double priority points on special days.
22
We have not made any significant changes to our priority seating 
model since the tax change in 2018 but have made internal changes 
Stanford including our recording of gifts, preferred gift methods, and how they count within university giving. We plan to continue to monitor our 
priority seating program to see if any changes need to be made if 
renewals drop due specifically to the tax laws.
University of We have not changed our structure.
California-Los
Angeles
We recently announced changes to our season ticket and benefits 
structure where we have combined the season ticket cost into one 
total. We are also now counting the total to donors’ annual benefits 
University of level. As far as points the only change is we are now providing 
Arizona priority points on the total of the season ticket cost and not just the 
amount that was a priority in the past. We implemented some 
renovations in our Skybox on our third floor but this wasn't tied to a 
tax law change. 
Table 9: Pac-12 Survey Question #2
Pac-12 3) What is your total donor count toward those three categories of 
Universities contribution for the years: 2017,2018, and 2019 (the total figure forall)?
Table 10: Pac-12 Survey Question #3
23
Discussion 
Pac-12 Seating Contribution Tables Discussion
In conclusion, both football and men’s basketball show evidence of an increase 
in donations in 2017 in anticipation of tax changes. It also appears that some donors 
may have shifted donations into 2017 for tax reasons, but no consistent evidence that 
overall giving to athletic departments has decreased in response to tax changes. It can 
be seen that both football and basketball trended downwards after the time of the tax 
change. Although there could be several reasons including the tax change for this 
decrease in total donations.
Pac-12 Survey Discussion
In summary, athletic departments saw an influx of donations in the November 
and December 2017 by offering donors a chance to make prepayments to seat 
contributions. Athletic departments allowed donors to donate up to three years in 
advance and capitalized on the contributions. The influx was part of regular donations 
along with tax change preparations. Three athletic departments made changes due to the
tax change while four athletic departments continued their operations without any 
changes. After the tax change, all athletic departments put emphasis on its already 
established priority point system for donors' benefit, except for the University of 
Washington, who does not have a points system, saw donor participation for Men's 
basketball and football trend downward after the tax change, but it is hard to know if 
that will continue in the long term.
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Donor interviews- Anecdotal Evidence
I had the opportunity to interview donors about their relationship with the 
University of Oregon and to learn about why Oregon is their institution of choice. Also, 
I questioned if the elimination of the Seating-Right Tax deduction had any sway on 
their decision to purchase the rights to season tickets. I previously predicted that most 
donors were transaction donors and because of this thought that the elimination of the 
deduction would have had an impact on the generosity of the donors. To my surprise, 
the responses I received demonstrated that the elimination of this write-off did not deter 
donations, in fact it seemed to have little to no impact on their generous gifts. I was 
delighted to hear that the people I spoke to were philanthropic donors, meaning their 
donations were given because of their love and passion for University of Oregon. They 
also felt that their donation came with a sense of pride, along with a stake in the 
University of Oregon causing them to be emotionally invested in the success in not only
the program(s) they donated to, but also the institution as a whole.
In asking why donors continue to donate to the University of Oregon, their 
responses varied, but one consistent similarity was rooted in childhood memories, 
volunteering, and family legacies. Two of the donors mentioned memories of attending 
an Oregon football game. One donor recounts the time he attended a University of 
Oregon football vs. Stanford game, while he was a student at another college, to see 
Dan Fotus and Jim Plunkett battle it out on the field. From that point forward, he was 
hooked on the University of Oregon. While the other donor remembered as a kid getting
the chance to meet Mel Renfro, his football idol. After a game, Mel gave the donor his 
chinstrap from his helmet as a gift and the donor still has it to this day. From that 
25
experience, he went on to both attend and play football at the University of Oregon, and
his kids followed his legacy. Donors also felt connected to the University of Oregon by 
volunteering. They helped establish and coordinate fundraising campaigns for different 
sectors of the university ranging from academics to sports. By staying involved, their 
relationship with the university continues to grow and they see how their impact on the 
university has lasting effects. 
Donors have been supporting the University of Oregon for over 100 years 
through their generous donations of both money and time. One of the donors 
interviewed has been involved with Oregon for over 40 years, with other donors only 
behind by 5 years or less, really speaking to the commitment each of them feel to the 
university. Each donor has been a season ticket holder for each football, men’s and 
women’s basketball, and baseball for over a decade. Each of them expressed a sense of 
pride with their contributions, stating it is the most rewarding investments they make 
because it gives them a chance to support student-athletes both financially and 
athletically as fans. 
Prior to 2018, all the donors were informed of the elimination of the Seating -
Right tax deduction in various ways. The main source of information came from the 
DAF. They reached out to all their donors in order to be transparent about the changes 
that were coming. Donors were initially surprised, but they were more concerned about 
how it would affect the athletic department revenue, which this paper is intended to 
address. After the news, a few donors decided to stop giving or were more conservative 
about their donations, causing them to consider which sports they wanted to continue to 
hold season tickets to, if any.
26
Overall, the majority of donors interviewed said the tax change has not affected 
their giving to football and basketball season tickets. Their love and sense of pride in 
both the football and men's basketball superseded a tax change, and they feel fortunate 
to have discretionary funds to spend on supporting sports programs. With the exception 
of one donor, donors did not itemize their taxes, nor did they even know they could 
claim a deduction. Additionally, a donor acquired more season tickets for both softball 
and women’s basketball due to the success both programs are seeing. This speaks to the 
culture of the Oregon donors and goes to show that a lot of them are philanthropic 
donors, rather than transactional, meaning the elimination of this deduction did not 
affect their willingness or desire to donate. In fact, many donors not only donate to the 
athletic fund, but also donate to many other programs across campus to help facilitate 
success. Evidence also suggests a correlation between a donors age and the number of 
season tickets they hold. When donors had families, they had more season tickets for a 
specific sport and as both donors and their children aged, the number of season tickets 
they purchased decreased.
27
Conclusion
The elimination of the Seating-Right Tax deduction, while not directly related to
the decrease in donations, is part of the reason athletic departments across the Pac-12 
are seeing a downward trend in donations. While the tax change may not affect the 
donor's willingness to donate as previously assumed, it was intriguing to learn more 
about the donors' reasoning as to why they may not be donating as much as in previous 
years, and to find out why the appeal of buying season tickets to football and basketball 
games continues to decrease. It is possible that as the donor's age, membership 
contributions decrease because they are on a fixed income after they retire, or because 
their interest and/or ability to attend games decreases. That leaves the question of if 
athletic departments are able to entice younger donors, who have less of a disposable 
income, with the cost of season tickets steadily increasing year over year. It is also 
possible that potential younger donors are not establishing their career in the same state 
as their alma mater, therefore not feeling connected enough to the university to donate. 
A way to counteract a potential loss of donors due to location would be to keep donors 
connected virtually, but also increase alumni outreach to help generate that sense of 
pride that has a lot of impact on the generosity of donation. 
While technology is another area that could help with donor outreach, it could 
also hurt the athletic department's ability to bring in donations for season tickets. 
Advancement in technology impacts stadium attendance, allowing fans to access games 
from their TVs, phones, tables and a multitude of streaming services and not having to 
attend the games in person. As a result, decreasing the athletic department’s revenue 
because it eliminates the need to be physically at the event.
28
Much has changed in our world since the initial writings of this thesis, and it is 
important to note the impact of COVID-19 and the repercussions that this outbreak 
could have on the football and basketball season, especially after seeing the cancellation
of winter sports championship games, and spring sports' seasons. The current situation 
nationwide promises to affect donations and funding for college sports in a way that no 
one could have anticipated, or easily remedy. There is no timeline as to when this will 
end, and therefore the future of these sports remains unknown. This could affect the 
overall revenue of the athletic departments in the Pac-12 way more than I ever 
anticipated the elimination of the Seating-Right Tax deduction would cause.
29
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