ATTORNEY MAKES CASE FOR COLLEGE CONTRIBUTION DEDUCTION

          In his "Tax Report" in the WALL STREET JOURNAL, Tom
     Herman wrote, "Athletic directors score in a high-stakes tax
     battle."  Herman: "When taxpayers give money to a collegiate
     athletic program, how much may they deduct as a charitable
     gift if they receive, in return, rights to purchase skybox
     seats at athletic events?"  The question "is very important
     to many colleges."  After a challenge by an IRS agent,
     Verner Liipfert attorney Philip Hochberg, representing the
     Div. I-A Athletic Directors Assoc., argued that an '88 law
     should allow 80% deductibility of amounts above the value of
     the tickets and "amenities," such as parking.  The IRS later
     "confirmed the 80% rule."  Hochberg called the decision "a
     critical financial one for major collegiate athletic
     programs, many of which have installed suites in stadiums
     and arenas in the past 10 years."   Herman wrote that the
     American Council on Education and the NCAA were "also
     interested in the issue" (WALL STREET JOURNAL, 8/11).