Augustin B. Jombo - Page 3




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          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:                                                             






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