Valuing Tickets and Passes to Events: How Much Are They Really Worth?

Between champion sports team events and world-class entertainment in Los Angeles, it is not unusual that tickets to special events can be a popular way for those doing business in the City to say "thank you." Unlike others, however, City officials and employees who are offered tickets to events have certain restrictions that govern the amount of gifts they can receive, and from whom they can receive them.

See related article, ‘Tis the (Approaching) Season: Gifts and Gift Limits for City Officials

In understanding how the gift limits work in practice, it is important to know the value of the gift that is being offered to you.

Some tickets to events have a stated face value that allows a City official to easily determine whether he or she can accept them and how the tickets should be reported. Other event tickets, however, do not, and it’s these tickets that can present the biggest challenge in determining their value. The following is designed to help City officials determine how state law values tickets to events so that can determine whether they can accept them.

Ticket to a political fundraiser or to a fundraiser for a 501(c)(3) non-profit organization

This ticket is exempted under state law and is, therefore, considered to have no value to the official. It may be accepted without restriction and is not required to be reported on the official’s financial disclosure form.

Ticket to a fundraiser for a 501(c)(4) or other tax-exempt non-profit organization

If the ticket has a clearly stated donation value, then the value is the cost of the ticket less the cost of the donation.

Example:
Ticket to fundraising dinner for 501(c)(4) = $100
Stated donation value on the ticket - $50
Value of Ticket = $50

If the donation amount is not stated, or the ticket has no stated price or face value, then the value of the ticket is the cost of the food and/or beverage consumed, plus the value of any other items received at the event.

Example:
Ticket to fundraising dinner for 501(c)(4) = no stated price
Stated donation value on the ticket - none
$20 steak dinner and goodie bag of $50 = $70

Event, Invitation-Only Event, Testimonial or Ceremonial Dinner

If an official attends an invitation-only event, or a testimonial or ceremonial dinner, then the value of the event is the official’s pro-rata share of the cost of the event, plus the value of any items received at the event.

Example:
Cost of invitation-only gala event = $100 per head
Value of goodie bag received + $40
Value of Event = $140

If an official does a “drop-in” at an event without having received or used a ticket, then the value of that event to the official is the cost of any food and/or beverages consumed, and any items received at the event.

Example:
Cost of invitation-only gala event = no ticket used
Value of food/beverages consumed + $15
Value of commemorative item received + $25
Value of Event = $40

One -Time Admission to a Sporting Event, Theater, etc.

If the ticket is also available to the general public, then the value is the face value of the ticket.

Example:
Face value of admission to concert = $175
Value of Event = $175

If the ticket is not available to public, or has no face value, then the value is the fair market value or the cost to the donor.

Example:
Ticket to preview of play that will cost $50 when the show opens to the public = $50
Value of Event = $50

Note: If the official does not use that ticket, and it is not transferred for use by another person, then the ticket has no value to the official who received it. Be aware, however, in situations where an official receives a ticket with a reportable value and chooses to transfer its use to another person, the value of the ticket is still reportable by the official. Because the official accepted control governing the use of the ticket, he or she is responsible for reporting its value on the official’s statement of economic interest.

Passes or Coupons for Repeated Admission to Movies, Sporting Events, etc.

If the pass is intended for the official only, the value of the pass or coupons is the fair market value of the pass.

Example:
Season pass to Disneyland = $300
Value of Pass = $300
If the pass also allows the official to bring additional guests, then the value of the pass is the fair market value of the pass, plus the value of any guest admissions.

Example:
Annual movie pass = $120
Guest admission-12/year at $10 each + $120
Value of Pass = $240

Quick Gift Check List

  • Identify the source of the gift and the gift amount you may accept from that source.
  • Identify the value of the item, or of the ticket or event by using this reference chart.
  • Call the Ethics Commission any time you have any questions.
  • Keep a record of any gifts you receive: reporting requirements may apply.

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