This week, college football bowl games dominate television sports programming. But, off screen, little-known tax breaks are spurring the latest scrimmage over commercialism in college athletics.

Some academics and legislators, contending that college football’s multibillion-dollar building boom detracts from schools’ educational mission, are targeting tax laws that treat payments for luxury seating and naming rights as charitable gifts.

Two congressional committees have looked into the tax breaks in recent months, seeking information from the National Collegiate Athletic Association and hearing testimony from critics. The tax benefits also have figured in a controversy at the University of Michigan over a proposed $226 million stadium renovation.

The tax perquisites, "could be the Achilles’ heel of stadium expansions, a way to put the brakes on," says former University of Michigan President James Duderstadt.

During the past decade, many football powerhouses, including Tennessee, have upgraded their stadiums, and the spending spree shows little sign of abating. Michigan plans to build 83 luxury suites at its stadium, known as "The Big House." The University of Texas recently embarked on a $175 million stadium reconstruction, adding 47 luxury suites. Partly as a result of debt payments on capital outlays, colleges’ athletic spending is increasing more than three times as fast as their overall spending, according to the NCAA.

Universities typically finance these renovations by issuing tax-exempt bonds. They then make payments on the debt by leasing the new luxury suites and other preferred seating to individuals or corporations. Suites — usually featuring 16 seats, catered food, televisions and high-speed Internet access — are priced at $50,000-$90,000 a year.

A selling point to alumni and other supporters is that they can deduct most of the lease fee from their taxable income. Under a 1988 federal law, taxpayers may deduct 80 percent of payment for the right to purchase seating at a collegiate sports event — though not a professional one — as a charitable contribution. Direct payments for game tickets, food, parking and other goods aren’t deductible as charitable contributions but may be written off as a business expense if used to entertain clients.

Some colleges also pay debt by selling stadium naming rights to corporations, which can deduct the payment as a donation or business expense. The University of Maryland this year sold naming rights to its football field for $20 million over 25 years to Chevy Chase Bank to help fund a $50 million renovation that also adds 60 luxury suites. Under a 1997 federal law, colleges don’t pay taxes on revenue from naming rights, which are considered part of their nonprofit mission, rather than unrelated business income.

College athletic directors and boosters say they need the tax breaks to raise revenue to modernize stadiums and pay for less-popular sports and academic tutoring for athletes. "I don’t see a thing in the world wrong with" the 80 percent deduction, says oil executive W.A. "Tex" Moncrief Jr., who leases a luxury suite at the University of Texas stadium. "That money is used to further many educational activities."

Warren Hood, associate athletic director at the University of Illinois, said the 80 percent deduction is cited in its marketing brochures and has been helpful in pitching luxury suites. Illinois, which lost 10 of 12 football games this season, began construction last month on a $116 million stadium renovation financed largely by borrowing. Hood said the university has commitments from supporters to lease 45 of 48 new luxury suites priced from $45,000-$59,000 a year.

Critics say these payments should not be deductible as charity because they purchase a valuable asset — either premium seating or, in the case of naming rights, advertising. The 80 percent deduction is "ridiculous," says Smith College economist Andrew Zimbalist, author of a book on college sports. "I don’t think intercollegiate sports support the educational mission. It’s a separate activity."

A tax deduction for luxury boxes "isn’t my style," says Rebecca McGowan, one of the University of Michigan’s eight regents. She initially opposed the Michigan renovation out of concern that skyboxes "were going to be enormously expensive, for the benefit of relatively few people." But she switched sides after receiving assurances that more athletic revenue would be devoted to academic programs.

Duderstadt, the former Michigan president, told the Senate Finance Committee at a hearing this month that the "perverse treatment" of "mandatory fees" for luxury-skybox leases and season-ticket licenses as charitable contributions is "fueling an arms race in college sports, driving universities to debt-finance massive stadium expansion projects, exploit young student athletes, and tolerate multimillion-dollar coaches’ salaries."

Iowa Sen. Charles Grassley, the outgoing Senate Finance chairman who will become ranking minority member in the next Congress, said through a spokeswoman that he’d "like to know how tax deductions for boosters who lease luxury boxes at college football stadiums help poor kids afford college." The incoming chairman, Montana’s Sen. Max Baucus, expects to focus on whether federal tax incentives "are helping to provide educational access to students," and may look at tax breaks for athletic facilities in that context, a senior aide said.

According to a staffer, Grassley is considering taking up the investigation initiated by retiring House Ways and Means Chairman Bill Thomas into whether sponsorships and huge television deals for sports are consistent with colleges’ tax-exempt status. In October, Thomas wrote to NCAA President Myles Brand, observing that major-college football and men’s basketball "more closely resemble professional sports."

The California representative, who copied Grassley on the letter, asked Brand how much money athletic departments receive from corporate sponsorships and donations, including gifts made for the right to buy tickets. Brand responded in November that sponsorships generate $275 million in annual athletic revenues and that donations to major-college athletic departments in 2004-05 were $845 million.

"Educational institutions ... have received favored status in every income tax act passed by Congress," Brand wrote.

Such consideration surfaces in the history of the 80 percent luxury-suite deduction. In 1986, the Internal Revenue Service ruled that gifts required to obtain a "substantial benefit," such as season tickets, are not deductible. Nevertheless, a tax-reform act passed that same year allowed full deductions for contributions for the right to buy seating at the University of Texas and Louisiana State University. The provision was pushed by the late Texas representative J.J. Pickle, a University of Texas alumnus and influential member of the House Ways and Means Committee, and the late Louisiana Sen. Russell Long, an LSU graduate and longtime member of the Senate Finance Committee.

In 1988, Congress extended the deduction to all universities but reduced it to 80 percent. "That was one of those blatant compromises," says Bruce Hopkins, a Kansas City, Mo., attorney specializing in nonprofit law. "They just plucked the 80 percent figure out of the proverbial air."