It’s a combination of things that makes all the sense in the world. It’s a forgone conclusion he’ll get out of state taxes. That’s 12% (so + $84m) for Cali. The question is, is he grandfathered into the 37% Fed rate, or does he pay more if it goes by deferral time. He wouldn’t be the first athlete to decide to live off his endorsements, and $50m year is living large. And there’s definitely a Tom Brady factor to it all. He wants to win.
Anyways, this is a unicorn situation and there’s no need to rewrite rules over it