accountants consulted by SI, Osweiler was liable for $600,000 in Colorado income tax based on his time spent in that state, plus another $150,000 to the other states in which he played in 2017. One accountant suggested a different possibility:One CPA suggests that Ohio and Colorado could both claim they deserve that $600,000, forcing an appeal and possible federal court case. The result could depend on whether the Browns paid Osweiler a lump sum before he left Ohio, or if he continued getting weekly payouts.(emphasis in original) Criticism of the "jock tax" In 2003, the Tax Foundation conducted a study on the jock tax. It concluded that the tax is: Poorly targeted Arbitrarily enforced Unrealistically burdensome to athletes According to the foundation, the jock tax "forces traveling professionals to file potentially dozens of state and local income tax returns annually." The foundation argues that the jock tax is poor tax policy. An analyst for the foundation pointed out in 2014 that because taxes are imposed on everyone who travels with a professional sports team, many individuals subject to the tax are not the stereotypical highly-paid athletes: Many trainers and scouts do not earn much more than the national median income, and players earning the league minimum in some leagues, such as Major League Soccer, earn only around $35,000 per year. This can lead to a substantial tax complexity burden because many team members have to file income taxes in around 15-20 states each year. ... the tax hits many people who may not be able to easily absorb the substantial compliance costs associated with the tax. The aforementioned 2018 SI story further illustrated this complexity. Because the Dallas Cowboys split their 2017 training camp between Oxnard, California and Texas, wide receiver Dez Bryant was subject to $10,000 in state income tax for every day the team spent in Oxnard. In the same year, the Miami Dolphins trained in Oxnard in the days following Hurricane Irma, subjecting the team's on-site personnel to California's income tax for that period. Ndamukong Suh was subject to more than $50,000 in California income tax during this time. One unnamed 2016 All-Pro had federal, state, and city tax filings for that year that totaled 400 pages, and during the team's bye week went on a vacation to income tax-free Florida that saved him $20,000 in income taxes. One major sports league was able to partly address