In April of 2022, Ochai Agbaji, 22 years old, was the star of the Kansas University basketball team and the most outstanding player of his team that won the NCAA basketball championship. As a result, Ochai was selected in the first round of the NBA draft in June of 2022 . In advance of the draft, Ochai was wined and dined by several sports agents, and each agent provided Ochai with "incentives" to be selected as his agent. These incentives ranged from trips to Las Vegas to Rolex watches. His parents were also being wined and dined in hopes that they could influence Ochai in his choice of agents. After finally selecting an agent, the time came to negotiate his contract with the basketball team that selected him. Ochai relied on the agent in these dealings as he does not have a lot of experience regarding the financial details of professional player contracts or the interworking of negotiations. Ochai's agent negotiated his contract with the Utah Jazz who ultimately selected Ochai in the NBA draft. The contract is for $3.9 million in salary for the first year, a $1 million signing bonus that was paid at the contract signing in August of 2022 , and incentive bonuses based on his and the team's performance plus fringe benefits. These benefits include health and dental insurance, life insurance, a team car, a clothing allowance, a travel allowance for him and his family, free tickets to each game, and all the training and fitness coaching he needs. Ochai has come to your firm for tax guidance regarding the package provided by his team as well as the "incentives" and other items provided by the agents that were enticing him to sign up with them as Ochai is wanting you to prepare his 2022 federal and state income tax returns. Provide an internal memo to the Ochai Agbaji client file, with an initial outline of tax issues associated with all the facts provided above. Your internal memo should include citations with respect to any statutes, regulations, and rulings (or cases, if applicable) that you reviewed in providing your initial assessment