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The rapidly expanding landscape of nonprofit collectives paying college athletes to promote charities has been hit with a potentially seismic disruption. A 12-page memo from the Internal Revenue Service released in June determined that in many cases, the nonprofit collectives may not qualify as tax-exempt if their main purpose is paying players instead of supporting charitable works. And if the collectives aren't tax-exempt, their donations to quarterbacks, point guards and pitchers may not be either. The founder of a collective tied to Ohio State athletics says it may cease operations in coming months.

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