The owner of an NBA arena is appealing an Ohio commercial activity tax (CAT) determination arguing that gross receipts from ticket sales of third-party events hosted at the arena are not attributable to the owner. When the arena was not being used by the Cleveland Cavaliers, the owner rented the facility to third-parties who host various entertainment events, such as concerts. As part of these arrangements, the arena owner sold tickets on behalf of the third-parties in return for certain fees or percentages of the net ticket sales. The Ohio Tax Commissioner determined that the gross amount of these ticket sales was attributable to the arena owner for purposes of the CAT because the owner held these funds in its bank account (regardless of any subsequent transfer to third-parties). In its appeal to the Ohio Board of Tax Appeals, the arena owner argues that temporarily holding the proceeds of ticket sales does not amount to a realization of gross income for purposes of the CAT and that these funds are statutorily excluded from its gross receipts under R.C. 5751.01(F)(2)(1) because it was merely an agent of the third-parties.