- 39 -
to dispose of his or her right thereto. We cannot realistically
accede to the view that an agreement for fixed payments backed by
the full faith and credit of a State government raises any such
concerns. Accordingly, even if applicable, this regulation would
not aid the estate.
We therefore hold that lottery payment installments at issue
here must be valued through application of the actuarial tables
prescribed under section 7520. Additional arguments by the
parties, to the extent not specifically addressed herein, have
been carefully considered but found unconvincing, irrelevant, or
moot.
To reflect the foregoing, and to take into account any
further allowable deduction under section 2053,
Decision will be entered
under Rule 155.
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