What is the “market value” of a ticket to an event with no entrance fee?  Event sponsors and executive branch employees have long struggled on the best way to estimate the market value of government employees attending free, especially invitation-only, events.  Finally, we have an answer.

The Office of Government Ethics (OGE) issued a legal advisory to explain how federal employees should calculate the “market value” of attending an event with no entrance fee.  The answer is to aggregate the market value of any food, beverages, entertainment, or other tangible benefit offered to attendees in connection with the event.  However, the cost the sponsor incurred to rent the venue does not need to be included.

To ascertain this value, an executive branch employee can estimate the market value by reference to the retail cost of similar items of like quality or rely on a per-person estimate provided by the sponsor of the event — unless the government employee finds the sponsor’s estimate to be implausible or inconsistent with a fair value estimate.