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Boosters started a nonprofit to pay Alabama athletes millions. Now, it’s shutting down.
Money for athletes, tax breaks for donors: What we know about Walk of Champions, Alabama’s failed NIL nonprofit.
By
It started with the promise of a $100,000 check.
In the spring of 2023, John Parker Wilson, the former Alabama quarterback, had a request for the Internal Revenue Service: grant us nonprofit status by March 31, or Walk of Champions will lose the money.
“If the Organization does not receive its exemption determination by this date it will not receive this crucial start-up funding and other similar contributions will also be at risk,” reads a letter included with documents Wilson sent to the IRS.
Wilson was president of Walk of Champions, the nonprofit set up to help hand out money to top athletes at the University of Alabama. There is also the university’s private NIL collective, Yea Alabama, set up for a similar reason. But the nonprofit arm would let donors reap tax benefits when giving to the organization.
Now, less than two years later, the organization is shutting down, Wilson told AL.com in a statement on behalf of Walk of Champions.
Ever since July 2021, when the NCAA adopted a policy allowing student athletes to be compensated for their personal brands, college athletics have been changing fast. There are a lot of unknowns, as programs everywhere scramble to adapt to new rules, new schemes and new ambitions for recruiting and paying top athletes.
“Out of an abundance of caution for our donors and charitable partners, Walk of Champions ceased accepting donations and implemented a plan to dissolve,” the group said in its statement to AL.com. Walk of Champions became a public charity on March 9, 2023.
The group said it decided to dissolve after the IRS issued a warning last year about NIL collectives. In a memo, the agency said collectives predominantly focused on “serving the private interests of student-athletes” don’t qualify as nonprofits because the athletes essentially don’t count as charity.
“Student-athletes are not themselves a recognized charitable class,” reads the memo from the chief counsel of the IRS.
[Read more: These are the power brokers behind Alabama and Auburn’s major NIL collectives]
Meanwhile, private collectives, like Yea Alabama at UA, formed all across the country to act as a go-between for student athletes and donors and businesses to facilitate name, image and likeness deals. So did the On to Victory collective at Auburn.
But as the model for NIL collectives continued to expand, UA’s stood out in the state by forming a nonprofit. Collectives across the country — at Ohio State, Texas, Michigan and Notre Dame — also formed nonprofits, tax records show. But not in Auburn.
“This was no longer about paying a student athlete $50 to sign an autograph or show up at a bar opening or do a Q&A on Zoom with a bunch of fans,” said Kristi Dosh, consultant and founder of Business of College Sports. “It became, you needed tens of thousands, or hundreds of thousands or even millions for one individual player.”
It’s impossible to know exactly how much NIL money is flowing through Tuscaloosa, as the Yea Alabama collective is a private business. But, federal tax filings offer a window into the plans for fundraising and budgets at the failed nonprofit, Walk of Champions.
Walk of Champions did not meet its initial goals of fundraising $6 million in 2023, tax records show. And though the IRS hasn’t cracked down on collectives, the agency is still considering how — and whether — organizations that pay athletes can qualify as charities.
When it formed in 2023, Walk of Champions told the IRS that it would serve “charitable and educational purposes.” And, the organization said it planned to fundraise millions of dollars to pay student-athletes leveraging their name, image and likeness.
Board members for Walk of Champions did not respond to requests for comment.
Yea Alabama previously advertised Walk of Champions on social media.
“Turn your pledge into impact by giving to our student-athletes through Walk of Champions, our new official charitable partner!” the collective said in an Instagram post last year.
But Yea Alabama updated its website sometime earlier this month, according to screen grabs captured by the Wayback Machine. The site doesn’t mention Walk of Champions. In an email to AL.com, Jay McPhillips, the executive director of Yea Alabama, said that it is a “completely separate organization from Walk of Champions.”
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Bryant-Denny Stadium ahead of Alabama football's Fan Day event.Matt Stahl | AL.com
A shifting model
Nick Patti is an attorney with Phelps Dunbar LLP, a firm in Mobile that works on NIL legal issues and represents athletes. He said he wasn’t surprised that Walk of Champions was being discontinued, amid legal questions about acting as a charity while paying athletes.
He said his firm advised a group in Florida against seeking 501(c)(3) status for a collective.
“We didn’t believe that it was something they were going to be able to accomplish,” he said. “The way I interpreted that IRS memo, we were going to fail.”
So how have organizations justified using their charity status to fundraise for paying athletes?
Here’s how it’s worked so far, according to Dosh: Donors give to the collective’s nonprofit. Then, the nonprofit pays student athletes to do something charitable, such as helping build a house for Habitat for Humanity or speaking at a charity fundraising gala. The donors get a tax deduction. And players make money.
Walk of Champions paid two student-athletes for promoting and attending an event for the Quarterbacking Children’s Health Foundation in 2023, per the tax records. The group, which is the charitable arm of Birmingham-based Monday Morning Quarterback Club, gives money to children’s charities across Alabama.
Michelle McIntyre, spokeswoman for Monday Morning Quarterback Club, said that Alabama quarterback Jalen Milroe and former linebacker Chris Braswell supported the nonprofit’s annual banquet in December. Both Milroe and Braswell received awards from Monday Morning Quarterback Club at the event.
Braswell posted a video with Milroe on Instagram on Dec. 12 advertising the organization’s event, introducing themselves and showing them signing jerseys and footballs and taking photos with attendees.
“Thanks to the Monday Morning Quarterback Club and Quarterbacking Children’s Health Foundation for all you do to provide funds to fulfill medical needs and support for Alabama children and young adults,” the post reads.
“The two student-athletes used their large social media followings to promote the QCHF and interacted with children affiliated with QCHF grant recipients and their families,” Walk of Champions said in its tax return. “The student-athletes’ work with the QCHF helped increase attendance at the event they attended, raised awareness for the QCHF, and provided training and experience to the student-athletes in the areas of community engagement.”
IRS records show that $10,000 paid to two unnamed student-athletes were the only player payments from Walk of Champions last year, far below the $5.7 million the organization said it planned to spend on NIL payments in 2023.
Fundraising falls short
When Walk of Champions first wrote to the IRS last spring, the organization said it planned to raise $6 million and spend nearly every penny on paying athletes. But, in a tax return filed this May, Walk of Champions reported that it brought in just under $1.5 million in donations in 2023, its startup year — mostly cash plus $50,000 in stock.
That includes the $100,000 startup check. It came from Michael and Kathy Mouron; Michael Mouron went on to join the organization’s board of directors.
Walk of Champions' budget in 2024
The nonprofit arm of NIL collective Yea Alabama submitted this budget to the IRS for its expenses planned for 2024.. It planned to bring in $8 million in revenue.Table with 2 columns and 13 rows.
Expenses | Amount |
---|---|
NIL payments to student athletes | $7,600,000 |
Fundraising expenses | $75,000 |
Other salaries and wages | $75,000 |
Professional fees | $25,000 |
Occupancy (rent, utilities) | $25,000 |
Software/subscriptions | $25,000 |
Marketing | $15,000 |
Office supplies | $5,000 |
Travel | $40,000 |
Benefits | $15,000 |
Insurance | $20,000 |
Credit card fees | $5,000 |
TOTAL | $7,925,000 |
[Can’t see the table? Click here.]
Most of the Walk of Champions budget for 2023 – $5.7 million, or 95% – was set aside as NIL payments to student athletes. The rest of expenses were for things like fundraising, office expenses, travel and marketing.
Walk of Champions told the IRS that in 2024 it expected to fundraise much more – $8 million – according to tax records. And the organization said it planned to spend nearly all of that money, $7.6 million, to make NIL payments to athletes.
[Can’t see the table? Click here.]
But now it’s stopped accepting donations and canceled future fundraising plans. That includes plans it sent to the IRS to raise $10 million in 2025.
Walk of Champions told AL.com it is distributing the money it’s already collected from donors to other charities or services. The group did not say how much money it has leftover to distribute.
If a collective that already achieved nonprofit status decided to discontinue operations, Patti, the attorney in Mobile, said he would advise the group to just return the donors’ money instead of redistributing the funding to other charities.
“That is going to be a messy process,” he said.
A warning from the feds
If the IRS chooses to crack down on these nonprofits, experts say, there could be a shakeup.
“I anticipate, whether it be through this tax year or maybe the next, you’re going to see some… donors that have donated and get some sort of a write-off for a donation to a collective that’s been created as a 501(c)(3),” Patti said, “or a collective that’s been operating as a 501(c)(3) that did obtain their status but will either have that revoked or face severe penalties from a tax standpoint from the IRS because they’re not actually operating like a nonprofit organization.”
Dosh added that she thinks most of the nonprofit collectives are “problematic,” but there are ways to adjust and still keep operating as nonprofits.
“It’s not like the IRS has stopped giving it out,” Dosh said. “They are still giving 501(c)(3) status to collectives. But we definitely saw a shift where a lot of 501(c)(3) collectives shut down, or they sort of got absorbed by the for-profit collective.”
In its memo last year, the IRS warned NIL collectives about the kinds of spending that could endanger their nonprofit status.
“Consequently, it is the view of this Office that many organizations that develop paid NIL opportunities for student-athletes are not tax exempt and described in section 501(c)(3),” the memo reads. “Student-athletes generally benefit from a nonprofit NIL collective through the compensation paid by the collective for use of their NIL. This private benefit is not a byproduct but is rather a fundamental part of a nonprofit NIL collective’s activities.”
Katie Davis, a CPA and partner with James Moore & Co. accounting firm in Florida, has worked with colleges on navigating NIL. She said there are two reasons why a nonprofit collective may wrap up operations following the IRS memo last summer.
One explanation could be that the IRS directly instructs them to do so – though, she said that’s rare because of the agency’s staffing challenges. The other is that the need for a middleman – especially one with the capability for tax-deductible donations – lessens with the NCAA’s move toward allowing universities to be more directly involved with NIL compensation.
“Theoretically, someone could probably give to the institution, and then that money works its way through. Even if their money doesn’t go directly to an athlete, it goes to the institution to replace funds that did go to an athlete,” she said. “I could see where universities and collectives might say, ‘It’s not worth the risk of having the spotlight on us and having the IRS make an example of us as we’re trying to navigate this new generation of college athletics, so let’s just not even go there anymore.’”
Wilson, who was the Alabama quarterback from 2006 to 2008, last August stepped down after five years as a color analyst for the team. He’s currently a financial advisor at Morgan Stanley, based in the Birmingham metro, per his LinkedIn page. Wilson played for the Steelers, Jaguars and Falcons in the NFL.
While he is the president of Walk of Champions, the nonprofit’s board members include:
- Elliot Maisel, who is chairman of the Mobile Airport Authority as well as chairman and CEO of Gulf Distributing Holdings, a beer distributor. He’s also worked at Herman Maisel & Company, another family company, for decades. He graduated from the University of Alabama in 1976.
Elliot Maisel is chairman of the Mobile Airport Authority. (John Sharp / AL.com)John Sharp
- Michael Mouron, who founded Capstone Development Corporation in 1990 and retired in 2012. Since then, he’s ventured out on his own, renovating buildings like the Federal Reserve Building and the historic Greyhound bus terminal in Birmingham, as well as joining the Valley Hotel as managing partner. He and his wife are donors to the University of Alabama, where he graduated in 1972.
- Annie Thompson Somerville, who is executive director of the Thompson Foundation, per her LinkedIn. She’s participated in fundraising efforts for the Birmingham Zoo and the United Way of Central Alabama. She graduated from the University of Alabama in 2014.
In Wilson’s initial appeal to the IRS for nonprofit status, he explained the mission of Walk of Champions.
“The Organization’s program builds on the University of Alabama’s dedication to helping students achieve their full potential and make a positive difference in their community,” the organization’s records for the IRS reads. “The Organization plans to partner with the University of Alabama to provide leadership opportunities to students, as well as to promote values of community service among its athletes.”
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