Drennan on Charitable Naming Rights

William Drennan (Southern Illinois) has published Where Generosity and Pride Abide: Charitable Naming Rights, 80 U. Cincinnati L. Rev. 53 (2011).  Here is a portion of the introduction:  

This Article asserts that the economic substance of a charitable contribution rewarded with naming rights is part gift and part purchase.  Data from other naming situations suggests that the lion‘s share of a naming philanthropist‘s total transfer to charity is an unrequited gift, but the data also suggests that a portion purchases a return benefit.  Accordingly this Article proposes that Congress should continue to allow deductions for the gift portion, but reverse course and prohibit income tax deductions for the naming portion. This Article also explores implementation issues.

LHM