For Justin Spooner, the pair of seats near the 50-yard line in West Stadium is a family heirloom.
"I'm not letting those go," he said, noting his grandfather first started attending Husker football games in the 1930s.
The tickets, though priced the same as virtually every one of the 90,000 other seats in Memorial Stadium, come with a required $2,000 per seat contribution to the Nebraska Athletic Department.
Similar donations — amounts vary — are tied to seats throughout the stadium, and in other sports. And it's not just a Nebraska thing. Donations tied to tickets are common for athletic departments across the country.
This month, those athletic departments, including Nebraska, are encouraging boosters and season ticket-holders to take advantage of a tax break before it disappears Jan. 1 as part of broad changes to the U.S. tax code.
Under the Tax Cuts and Jobs Act signed into law by President Trump on Dec. 22, alumni and fans making annual donations for the right to purchase season tickets will no longer be able to claim a tax deduction totaling 80 percent of their donation.
Based on the location of seats in Memorial Stadium, some Nebraska football season ticket-holders can be asked to contribute as much as $2,500 per seat each year, even before purchasing their ticket packages. For those ticket holders, the annual deduction was $2,000.
“As a reminder regarding the new bill, the IRS will no longer recognize seat-related contributions as tax deductible as of January 1, 2018,” the Nebraska Athletic Department wrote in a Dec. 20 email to season ticket-holders.
Steve Arneal, who first bought season tickets two years ago after retiring from his farm near North Bend, took advantage of the opportunity before New Year's Day.
“Normally, I had paid it later, whenever it was due. Not this early,” he said this week.
For $500 each year, he retains the right to purchase the two seats “up there with the birds” in East Stadium he's shared with his son the last two seasons.
“This is one of the few things we did because of the change to the tax law,” he said of making the 2018 donation early, adding he believed there was reform needed to the nation’s tax code. “There might be a few more things we ought to be doing.”
After missing season after season of Husker home games because of harvest, Arneal said the elimination of the tax deduction likely won’t stop him from making donations tied to buying tickets in future seasons — particularly as the Scott Frost era begins.
But Spooner, 27, said he'll reassess his decision next year.
He made his 2018 donation last week in order to deduct the contribution from his 2017 taxes — which he said allows him to finance other donations toward causes he cares about — as well as to capture bonus priority points that the athletic department uses in allotting tickets to NCAA championships and bowl games.
"You really have to weigh the cost," Spooner said. "For me, from a family tradition standpoint, it's worthwhile, but I could see where it would be hard for a lot of people to justify paying the cost if they think the athletic department doesn't need it."
Contributions from loyal fans helped the Husker athletic program rake in $21.5 million in 2016, according to a report by USA Today, equating to more than 19 percent of the department’s total revenue of $112 million.
Combined with rights and licensing fees ($48.3 million in 2016) and ticket sales ($37.2 million), donations help keep Husker Athletics competitive without relying on additional support from the university, state appropriations or student fees.
In fact, with Nebraska's Big Ten membership paying off more this year, the athletic department is expected to return approximately $10 million to the university’s academic and research arms, a department spokesman said.
But allowing season ticket-holders to deduct 80 percent of the donation they make to athletic departments before purchasing their seats has long been criticized by tax experts and advocates calling for an overhaul of college sports, many saying the provision is a subsidy to wealthy fans.
The Obama administration tried to end the tax write-off in 2015, but was blocked by Republican lawmakers before the GOP included it in its own tax reform bill passed by both the House and Senate this year.
According to an estimate by the Joint Committee on Taxation, eliminating the deduction tied to season ticket-related donations will generate $1.9 billion in federal tax revenue over the next decade.
Although not all donations are tied to season-ticket purchases, college sports powerhouses such as Alabama and Oklahoma have raised concern over how eliminating the deduction might affect their programs and encouraged fans to consider buying several years’ worth of tickets early, capturing tax benefits in the process.
The Nebraska Athletic Department said it was too early to say if more alumni and fans had given this year compared with previous years, but that the department has seen a “good response from donors choosing to submit their contribution before the end of the year.”
“Our donors always have the opportunity to submit their contributions before December 31, and we have made them aware of the advantages of doing so this year,” the department said in an email. “We are encouraging our donors to consult a tax adviser if they have questions.”