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This case was submitted fully stipulated under Rule 122.1
The stipulation of facts and the attached exhibits are
incorporated by this reference. At the time of filing the
petition, petitioner resided in Cherry Hill, New Jersey.
On December 7, 1992, petitioner won $9,397,987.40 in the New
Jersey State Lottery’s (NJSL) Pick-6 Lotto Drawing. According to
rules and regulations governing the NJSL in 1992, petitioner was
to receive the lottery winnings in 20 annual pretax installments:
The first installment was $467,987.40, and the remaining 19
annual installments were $470,000 each. Petitioner had purchased
his winning lottery ticket for $1.
According to New Jersey State law, petitioner was required
to obtain approval from the Superior Court of New Jersey before
he could transfer his rights to receive future lottery winnings.
Petitioner obtained the superior court’s approval to assign his
lottery prize payments to Singer Asset Finance Co., L.L.C.
(Singer).
On December 23, 1996, petitioner assigned his rights to
receive three of the annual lottery payments of $470,000 each,
scheduled to be made on December 8 or 9 of 1998, 1999, and 2000,
to Singer in exchange for $1,113,500. On August 27, 1997,
1All Rule references are to the Tax Court Rules of Practice
and Procedure, and all section references are to the Internal
Revenue Code as amended.
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Last modified: May 25, 2011