The Podunk Shooters, a new professional basketball team, is slated to begin play in the 2023/2024 season with its first game scheduled for October 1, 2023. On July 8, 2021 its ownership group was chosen to receive the franchise following a highly competitive process. The Shooters begin selling season tickets for its inaugural 2023/2024 season on July 15, 2021. By November 30, 2021, 80 percent of the tickets for the 2023/2024 season had been sold, with the Shooters receiving $285 million of sales proceeds by June 30, 2022. The Shooters properly elected as its taxable year a fiscal year ending June 30. On its first tax return for the period ending June 30, 2022, the Shooters did not include any part of the $285 million from ticket sales in its gross income. Similarly, it excluded those sales, plus another $90 million of sales in fiscal 2023, from its tax return for its year ending June 30, 2023. Instead, it included the entire $375 million in its return for the fiscal year ending June 30, 2024. The Internal Revenue Service audited the June 30, 2022 return and determined that based upon provisions added to the Internal Revenue Code enacted as part of the Tax Cut and Jobs Act of 2017, $285 million of ticket sales must be included in the June 30, 2022 tax return and $90 million must be included in the June 30, 2023 tax return. What arguments would you make on behalf of the Service and the Shooters