[SkiBum80]

Has the IRS indicated the tax status of NIL payments?  It is hard for me to see how they would be tax deductible. That would seem to impact how much potential donors pay. Big advertisers would pay for (true) NIL  but donors may not pay as much in (pay-to-play) NIL as they have in donations to an educational institution.

From a tax advising company. Cannot personally vouch for it's accurateness.
I can say that my donation to Lifetime Cardinal gave a receipt with no indication it was tax deductible nor that Lifetime Cardinal was a 501c3.

Payments to NIL collectives
NIL collectives pool cash from boosters to provide opportunities for student-athletes. They’re often founded by prominent alumni and influential supporters, and they pool funds from several donors and businesses, help facilitate NIL deals for athletes, and/or assist in providing benefits to enrolled student-athletes or their family members.
Initially, many of these collectives were set up as 501©(3) nonprofit organizations, which allowed contributions to the collective to be tax-deductible charitable contributions. However, in June 2023, the IRS Office of Chief Counsel released a memorandum (AM 2023-004) that concluded that contributions to NIL collectives are not tax-deductible charitable gifts “because the private benefits they provide to student-athletes are not incidental both qualitatively and quantitatively to any tax-exempt purpose furthered by that activity.
This memo is a sign that the IRS will deny new applications for 501©(3) status from collectives and may revoke the status granted to other collectives through audits.

[SkiBum80]

Has the IRS indicated the tax status of NIL payments?  It is hard for me to see how they would be tax deductible. That would seem to impact how much potential donors pay. Big advertisers would pay for (true) NIL  but donors may not pay as much in (pay-to-play) NIL as they have in donations to an educational institution.

From a tax advising company. Cannot personally vouch for it's accurateness.
I can say that my donation to Lifetime Cardinal gave a receipt with no indication it was tax deductible nor that Lifetime Cardinal was a 501c3.

Payments to NIL collectives
NIL collectives pool cash from boosters to provide opportunities for student-athletes. They’re often founded by prominent alumni and influential supporters, and they pool funds from several donors and businesses, help facilitate NIL deals for athletes, and/or assist in providing benefits to enrolled student-athletes or their family members.
Initially, many of these collectives were set up as 501©(3) nonprofit organizations, which allowed contributions to the collective to be tax-deductible charitable contributions. However, in June 2023, the IRS Office of Chief Counsel released a memorandum (AM 2023-004) that concluded that contributions to NIL collectives are not tax-deductible charitable gifts “because the private benefits they provide to student-athletes are not incidental both qualitatively and quantitatively to any tax-exempt purpose furthered by that activity.
This memo is a sign that the IRS will deny new applications for 501©(3) status from collectives and may revoke the status granted to other collectives through audits.