119 T.C. No. 1 UNITED STATES TAX COURT JAMES F. DAVIS AND DOROTHY A. DAVIS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6389-01. Filed July 3, 2002. Ps assigned to S their right to receive a portion of each of certain future annual lottery payments in exchange for a lump-sum payment to them by S of $1,040,000. Held: S paid Ps a lump-sum amount for the right to receive certain future ordinary income. Held, further, Ps’ right to receive certain future annual lottery payments does not constitute a capital asset within the meaning of sec. 1221, I.R.C. Held, further, the $1,040,000 that Ps received from S is ordinary income. Donald J. Gary, Jr., for petitioners. Thomas J. Fernandez, for respondent.Page: 1 2 3 4 5 6 7 8 9 10 11 12 Next
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