NCAA tax exemption - Part I

For my first sports business post, I want to take on the fascinating issue of the NCAA's tax exemption.  For those of you who don't know me, I am not being sarcastic.  I actually find this stuff interesting. 

By way of background Bill Thomas, the Chairman of the House Ways and Means Commission, sent Myles Brand, the NCAA President, a letter questioning the NCAA's tax exemption.  Thomas noted:

To be tax-exempt . . . the activity itself must contribute to the accomplishment of the university's educational purpose (other than through the production of income). How does playing major college football or men's basketball in a highly commercialized, profit-seeking, entertainment environment further the educational purpose of your member institutions?

Brand's answer is at http://taxprof.typepad.com/taxprof_blog/2006/10/house_questions.html.  In this series of posts I will address the NCAA's response.