T.C. Memo. 2003-140
UNITED STATES TAX COURT
CHARLES JOHNS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9814-02. Filed May 19, 2003.
Robert E. Salad and Joel L. Schwartz, for petitioner.
Carol-Lynn E. Moran, for respondent.
MEMORANDUM OPINION
RUWE, Judge: Respondent determined a deficiency in
petitioner’s Federal income tax of $276,387 for 1998. The only
issue for our decision is whether the amounts that petitioner
received in exchange for his assignments of his rights to receive
certain future annual lottery payments represent ordinary income
or capital gains.
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