Shirley B. Prebola n.k.a. Shirley D. Begy - Page 1
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T.C. Memo. 2005-261
UNITED STATES TAX COURT
SHIRLEY B. PREBOLA n.k.a. SHIRLEY D. BEGY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4117-04. Filed November 8, 2005.
Gerald W. Dibble, for petitioner.
Kevin M. Murphy, for respondent.
COHEN, Judge: Respondent determined a deficiency of
$1,310,766 in petitioner’s Federal income tax for 2000. The
deficiency was attributable to respondent’s recharacterizing the
lump-sum proceeds received by petitioner for the sale of rights
acquired from the New York State lottery as ordinary income
instead of capital gain. Unless otherwise indicated, all section
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Last modified: May 25, 2011