Yeah, seems like there are a few different factors at play.
Hobby Loss rules exist so somebody can't deduct their personal recreational expenses and call it a business. Like if I'm into motorcycles and spend $50k/year on things pertaining to them, I can't give a few lessons here and there that total $10k and then just deduct $40k on my tax return every year.
So I'm sure some of these guys are playing it safe and just flat out not deducting the payments if they're from some LLC they've established or something and they're not bringing in any revenues pertaining to anything a collegiate athlete would have something to do with. IRS wouldn't care about that, because they're taxable to the recipient so it's a net win.
For a collective like Alliance 412, I assume they have some non-profit status and basically operate at a breakeven. I know they pay wages to at least some of the people affiliated with it, so those are obviously taxable (in addition to the distributions to players, though most are probably below the standard deduction anyway).
But then you have these established companies like Tyson, FedEx, etc. That one kind of confuses me. Maybe not so much from a tax standpoint (deduction on one side; income on the other side... though obviously they're in different tax situations so it's not a net zero), but definitely from a duty to shareholders standpoint. Some of these payments are like 50x above fmv.
But, I concede that people a lot more knowledgeable than me have this all figured out or else it wouldn't be happening out in the open as it is.