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petitioners’ right to receive future annual lottery payments does
not constitute a capital asset within the meaning of section 1221
and that the $1,040,000 that petitioners received from Singer is
ordinary income, and not capital gain. See United States v.
Midland-Ross Corp., 381 U.S. at 57-58; Commissioner v. Gillette
Motor Transp., Inc., 364 U.S. at 134-135; Commissioner v. P.G.
Lake, Inc., 356 U.S. at 265-267; Hort v. Commissioner, 313 U.S.
at 31.
We have considered all of petitioners’ arguments and conten-
tions that are not discussed herein, and we find them to be
without merit and/or irrelevant.
To reflect the foregoing,
Decision will be entered for
respondent.
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Last modified: May 25, 2011