Capital Gains
In a recent legal memorandum — LAFA 20092102F — the Internal Revenue Service addressed the quirky issue of whether a personal seat license and the related right to purchase season tickets for a professional sports team constituted “property or the right to property” subject to seizure and sale by the IRS. In the memorandum, the IRS concluded that the personal seat license is property subject to seizure and sale but that the renewal right to the season tickets is not a property right subject to seizure or sale.
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