[SkiBum80]

...I'll bet dollars to donuts that there will be much litigation.

I think it depends on what your definition of "much" is.
If you mean a lotta lawyers involved I'd agee.
But if you mean a lotta cases, I actually kind of doubt it.
I think there will more likely be one (or two) strategic cases that ever go to trial, which I think the IRS will win decisively.
Holding in court that there is no way donations to an organization that is primarily meant to funnel NIL cash to college athletes is in any way a charitable donation for tax purposes.
After one (or two) big wins for IRS, there may not be any more similar cases for awhile.
Such my expectation.

[SkiBum80]

...I'll bet dollars to donuts that there will be much litigation.

I think it depends on what your definition of "much" is.
If you mean a lotta lawyers involved I'd agee.
But if you mean a lotta cases, I actually kind of doubt it.
I think there will more likely be one (or two) strategic cases that ever go to trial, which I think the IRS will win decisively.
Holding in court that there is no way donations to an organization that is primarily meant to funnel NIL cash to college athletes is in any way a charitable donation for tax purposes.
After one (or two) big wins for IRS, there may not be any more similar cases for awhile.
Such my expectation.