- 7 - partnership, the partnership’s right to receive the lottery payments must be assigned a value. Sec. 20.2031-3, Estate Tax Regs. The sole issue for our consideration is whether the partnership’s right to a fixed stream of lottery payments should be valued using the annuity tables in section 20.2031-7, Estate Tax Regs. As an initial matter, the estate argues that the partnership’s right to receive lottery payments is not an annuity. Respondent argues that the partnership’s right to receive lottery payments is an annuity which must be valued using the annuity tables. At the time the petition was filed in this case, that question had not been addressed by this Court. However, the question of whether lottery payments should be treated as an annuity was recently answered in Estate of Gribauskas v. Commissioner, 116 T.C. 142 (2001), a case involving substantially similar circumstances to those before us. In Estate of Gribauskas, the decedent and his former spouse won a Connecticut Lotto prize. Within a year after winning the lottery they divorced, and soon after, the decedent died owning the right to receive half of 18 annual, unassignable, nontransferable payments that could not be distributed in one lump sum. The estate elected an alternate valuation date of December 3, 1994.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011