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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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