Roland and Marie Womack - Page 19
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unpersuaded that those statutes and definitions have any
relevance to the question we consider. In addition, even if they
are analogous, petitioners’ intent is to show that such
definitions support their argument that lottery rights are
capital assets within the meaning of section 1221. As we have
already observed, the substitute for ordinary income doctrine
applies to the lottery rights petitioners sold irrespective of
whether they may be comparable to the categories defined in
section 1221 as capital assets. See also United States v.
Maginnis, 356 F.3d at 1187 n.10.
We have considered petitioners’ remaining arguments.
Because of the extensive precedent to the contrary, there is no
need for any additional discussion in this opinion.
To reflect the foregoing,
Decisions will be entered for
respondent in docket No. 13434-03 and
under Rule 155 in docket No. 19829-03.
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