Lance Strongarm, a recently retired professional athlete, is writing his memoirs. He intends to direct any royalties received on the book to his favorite charitable organization. He has not yet signed a contract with a publisher. Will the future royalties be included in Lance’s taxable gross income? Why or why not? If your answer is yes, is any alternative arrangement available that Lance might make to avoid gross income recognition? Prepare a written memorandum stating the research issue(s), your conclusions concerning the issue(s), and the specific statutory, regulatory, or judicial authority supporting your conclusions.