This past summer the NCAA legislated that college athletes may profit from their name, image, and likeness. A few La Salle University athletes have approached you about the use of their names to promote athletic footwear and apparel manufactured and sold by Adidas Corporation. Adidas has offered considerable money to some La Salle athletes in exchange for the right to use the athlete's name on a new line of athletic shoes as well as advertising and promotion campaigns associated with the sales of these shoes.

If these athletes decide to sign the contract and receive money, will they recognize gross income? If yes, is the payment considered ordinary income or capital gain?

Prepare a memo to the file communicating your tax research results.