Would the CCA have had to fill out a form 990 on these donations?
Yes, assuming the Casino Collectibles Association (CCA) was required to file IRS Form 990 for 2023, a donation of casino chips valued at approximately $800,000 to $1 million would generally have to be reported.

And here's the important part: The CCA would generally have to report the value of the donated collection even if it never sold a single chip.

However, there are different reporting requirements depending on the organization's tax-exempt classification, annual receipts, and which version of Form 990 it was required to file.

What we should be looking for
For the 2023 tax year, when Spragg says the collection was received:

IRS document

What it could tell us

Form 990, Part VIII

Value of noncash contributions received

Form 990, Schedule M

Types and quantities of noncash contributions

Form 990, Part X

Assets held by the organization at year-end

Form 990, Schedule B

Certain information about substantial contributors, with public disclosure restrictions

Form 8282

Whether qualifying donated property was disposed of within three years

A donation this large would ordinarily make Schedule M particularly relevant if the CCA filed the full Form 990.

I found the CCA's actual 2023 IRS filing
CCA • Fiscal year 2023 • Form 990-EZ

Reported contributions

$1,101
Total year-end assets

$190,798
Source: CCA's 2023 Form 990-EZ, filed February 19, 2025, as summarized by ProPublica.

ProPublica
This raises a serious question.

Spragg publicly stated in June 2023 that the club had received donations appraised at approximately $1 million.

Yet its 2023 return reports only $1,101 in contributions.

The CCA filed Form 990-EZ, not the full Form 990. Schedule M therefore would not apply in the same way. But the IRS instructions for Form 990-EZ generally require donated property to be reported at fair market value when received.

Internal Revenue Service

There are possible explanations, including differences between the claimed appraisal and the value recognized for tax reporting, or whether the CCA actually received ownership of the property.

I would not conclude that the return is incorrect until we inspect the original filing and establish the donation's legal ownership and valuation.

But the discrepancy is substantial enough to investigate.