The Big Ten uses its property for administration of intercollegiate sports programs. The work involves negotiation of television contracts for coverage of some intercollegiate games. There, as here, a state statute exempted real estate from property tax if the property was used exclusively for educational purposes. There is no serious contention that, generally speaking, physical education and sports programs in universities are not within proper 'educational purposes' and we must conclude they are educational. But such is not the issue.
Sports are a legitimate part of collegiate education.
Whether collegiate football and basketball, as they presently exist, are too large and too commercial are philosophical questions outside the issues of this action. No authority has been cited nor has our research disclosed any instance where a university's football stadium or gymnasium has been held taxable on the basis such facilities are commercial or entertainment facilities. The present large size of the NCAA arises from the great popularity with the general public of collegiate football and basketball events. This popularity spawns a myriad of problems such as improper recruiting practices which only the NCAA can properly control. The reasoning applied by the BTA appears to be that at some point a collegiate sport may cease to be an educational activity and become merely entertainment.