Since 2004, the Commitee on Ways and Means of the U.S. House of Representatives has been conducting a broad review of the tax-exempt sector. As the sector increases in size, scope, and economic impact, the need for Congress to conduct comprehensive oversight grows as well.

Educational organizations comprise one of the largest segments of the tax-exempt sector, and most of the activities undertaken by educational organizations clearly further their exempt purpose. The exempt purpose of intercollegiate athletics, however, is less apparent, particularly in the context of major college football and men's basketball programs.