IRS can't seize rights to season tickets

The IRS can't seize a taxpayer's right to renew his season tickets to a professional sports team's games but could levy against his deposit for the tickets, under an advisory opinion from the Internal Revenue Service.

A taxpayer failed to pay his federal taxes and the IRS issued a levy against

According to the sports team's policy, the taxpayer's renewal rights were not transferable, and if he failed to renew his tickets, they would pass to a waiting list of people seeking season tickets. The sports team has a waiting list with thousands of names on it.

The IRS proposed to seize and sell the taxpayer's season ticket renewal rights as part of his "property or rights to property" under federal law.

The team objected to the sale but indicated that if it received a levy, it would pay out the taxpayer's deposit for the personal seat licenses.