StubHub, Inc. v. Wisconsin Department of Revenue

CourtCourt of Appeals of Wisconsin
DecidedJanuary 13, 2026
Docket2024AP000455
StatusPublished

This text of StubHub, Inc. v. Wisconsin Department of Revenue (StubHub, Inc. v. Wisconsin Department of Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals of Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
StubHub, Inc. v. Wisconsin Department of Revenue, (Wis. Ct. App. 2026).

Opinion

COURT OF APPEALS DECISION NOTICE DATED AND FILED This opinion is subject to further editing. If published, the official version will appear in the bound volume of the Official Reports. January 13, 2026 A party may file with the Supreme Court a Samuel A. Christensen petition to review an adverse decision by the Clerk of Court of Appeals Court of Appeals. See WIS. STAT. § 808.10 and RULE 809.62.

Appeal No. 2024AP455 Cir. Ct. No. 2023CV665

STATE OF WISCONSIN IN COURT OF APPEALS DISTRICT I

STUBHUB, INC.,

PETITIONER-CROSS-RESPONDENT-RESPONDENT,

V.

WISCONSIN DEPARTMENT OF REVENUE,

RESPONDENT-CROSS PETITIONER-APPELLANT.

APPEAL from an order of the circuit court for Dane County: STEPHEN E. EHLKE, Judge. Reversed.

Before White, C.J., Colón, P.J., and Geenen, J.

¶1 COLÓN, P.J. The Wisconsin Department of Revenue (DOR) appeals from an order of the circuit court reversing a decision of the Wisconsin Tax Appeals Commission (the Commission). In its decision, the Commission found that StubHub, Inc. (StubHub) was subject to the sales tax, see WIS. STAT. No. 2024AP455

§ 77.52(2)(a)2. (2023-24),1 for the sales of admissions to recreational events in Wisconsin that occurred through its online platform from 2008 to 2013. However, the Commission also found that StubHub was not subject to the penalty for StubHub’s failure to pay the sales tax, see WIS. STAT. § 77.60(4), during those same years. We conclude that StubHub is both subject to the sales tax and the penalty for its failure to pay the sales tax. Thus, for the reasons set forth below, we reverse the circuit court’s order.

BACKGROUND

¶2 StubHub operates an online marketplace where tickets to sporting events, concerts, theatre, and other live entertainment events are bought and sold. To use StubHub’s online marketplace, both ticketholders2 and ticket buyers register for an account with StubHub. As part of the account registration, users were required to accept StubHub’s User Agreement that contained terms and conditions governing their use of StubHub’s website.

¶3 Ticketholders using StubHub’s online marketplace listed tickets for sale. To list a ticket for sale, ticketholders were required to (1) identify the event using StubHub’s online catalog of events or, if none existed, ask StubHub to create a new event; (2) enter the ticket details, including venue, date, time, seat location, delivery method, and any other relevant details; and (3) set the ticket price. Tickets remained available on StubHub’s website unless withdrawn by the ticketholder or StubHub received payment from a ticket buyer for the purchase of

1 All references to the Wisconsin Statutes are to the 2023-24 version. 2 We use the term ticketholder as used by the parties to refer to a person who sold tickets on StubHub’s website.

2 No. 2024AP455

the ticket. StubHub generally did not limit a ticketholder’s ability to withdraw ticket listings, change the price, or sell a ticket elsewhere. The only exception to this practice was a ticketholder who chose to use the Instant Download option, in which case the ticketholder was required to list tickets exclusively with StubHub. If a ticket did not sell, the ticket remained with the ticketholder. Ticketholders who listed tickets on StubHub’s website tended to be individuals; however, other ticketholders who listed tickets on StubHub’s website were entities in the business of buying and reselling tickets. StubHub itself never bought tickets to sell on its own behalf or to hold for future sales.

¶4 At the time of a sale, the ticket buyer paid the ticketholder’s listing price plus any fees charged by StubHub. StubHub’s fees were equal to a percentage of the sale plus a logistics fee, which varied from sale to sale. StubHub collected payments from ticket buyers and, after taking its fees, returned the remainder of the payment to the ticketholder. StubHub’s revenue came from the fees that it collected when a ticket sold.

¶5 For the transfer of hardcopy tickets following a sale, StubHub provided instructions for ticketholders on mailing or delivering tickets to the ticket buyers. For transfer of electronic tickets, StubHub provided direct access to ticket buyers through its website. Pursuant to agreements with the organizations, tickets sold for Milwaukee Brewers games and University of Wisconsin football, basketball, and hockey games followed a process of “barcode integration” where the ticketholders uploaded the barcode number for the ticket and a new ticket was issued to the ticket buyer. Finally, in some limited instances, tickets were physically transferred in person using a service called Last Minute Transactions when a ticket was sold shortly before the event. As a result of this process, ticketholders and ticket buyers were generally unaware of the other’s identity, and

3 No. 2024AP455

StubHub only disclosed the identity of ticketholders or ticket buyers under limited circumstances.

¶6 As part of this process, StubHub provided a guarantee—called the FanProtect Guarantee—to ticket buyers that StubHub would find suitable replacement tickets or issue a full refund if the ticket buyer did not receive the tickets in time, if the tickets were not valid, or if the tickets received were not what the ticket buyer purchased.

¶7 During the years 2008 to 2013, nearly $154 million in ticket sales occurred through StubHub’s online marketplace for events that took place in Wisconsin.3 The record contains no evidence that ticket buyers paid any sales or use taxes on ticket purchases made through StubHub, and StubHub itself paid no taxes on the sales either. There is also no evidence in the record as to what, if any, sales or use tax was paid by ticketholders on the original purchases of the tickets later sold on StubHub. However, the parties stipulated that it was “highly likely” a tax was charged on the original ticket purchases in most cases.

¶8 In 2014, DOR notified StubHub that it would be auditing StubHub’s sales and use tax payments for the years 2008 to 2013. Following the audit, DOR issued a Notice of Field Action and Field Audit Report and assessed $8,495,937.50 in back taxes, plus another $8,567,136.15 in interest, penalties, and fees. DOR assessed a 25% negligence penalty because DOR found that StubHub negligently ignored published guidance in two tax bulletins indicating that

3 More specifically, the audit revealed total sales for each year as follows: $17,063,547.74 in 2008, $18,221,690.32 in 2009, $19,090,025.32 in 2010, $34,952,399.53 in 2011, $31,923,811.74 in 2012, and $32,299,811.57 in 2013.

4 No. 2024AP455

StubHub was responsible for paying Wisconsin’s sales or use tax. DOR denied StubHub’s petition for redetermination, and StubHub appealed to the Commission.

¶9 After a hearing, the Commission granted summary judgment in part to DOR and found that StubHub was subject to the sales tax. On the other hand, the Commission also found that StubHub was not subject to the penalty for its failure to pay the sales tax and reversed DOR’s imposition of a penalty against StubHub for StubHub’s failure to pay the sales and use tax. Thus, the Commission also granted summary judgment in part to StubHub.

¶10 More specifically, the Commission rejected StubHub’s characterization of its role as a passive online marketplace and found that StubHub’s imposition of fees on a per transaction basis, specific ticket transfer processes, and proprietary software “go further than what the Commission would consider [a] passive role” and transformed StubHub into a seller transferring tickets between the ticketholders and ticket buyers.

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StubHub, Inc. v. Wisconsin Department of Revenue, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stubhub-inc-v-wisconsin-department-of-revenue-wisctapp-2026.