- 3 - Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Some of the facts have been stipulated and are so found. Petitioner resided in the United Kingdom when he filed his petition. He has a master’s degree in business administration. Petitioner began working as a clerk for the Consulate General of Nigeria in New York City in 1987. In 1989, petitioner bought 12 NYSL tickets for $1 each. On January 4, 1989, petitioner won about $26 million from the NYSL, payable in 20 equal annual installments beginning in 1989. The NYSL did not offer petitioner the option of receiving a lump-sum payment in 1989. Petitioner was employed by the Consulate General of Nigeria when he won the lottery. He used the cash method of accounting in 1989. Petitioner received two or three offers to buy the rights to his future lottery winnings for about 50 cents on the dollar. He did not sell his rights. Petitioner acquired permanent U.S. resident status on November 24, 1989, and he maintained that status in 1996. The NYSL paid petitioner $1,238,100 in 1996. On a Form 8275, Disclosure Statement, attached to his 1996 return, petitioner reported that he received $1,238,100 from the NYSL, and said:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011