Many professional sport organizations allow season ticket holders to renew their purchases each year. The IRS has ruled that it cannot seize and sell an individual’s season ticket renewal because it isn’t considered property or a right to property under state law but that the individual does have a property right in the personal seat licenses that the IRS can levy. Under section 6331 that IRS can seize and sell an individuals season ticket renewal deposit. The IRS determined that if a team allows a season ticket holder to transfer ticket renewals, either by policy or in practice, then a right may exist. Therefore, the IRS can exercise the taxpayer’s right to terminate the season tickets and receive a refund of the personal seat license deposit but they cannot sell the season ticket holders right to renewal.