T.C. Memo. 2003-155
UNITED STATES TAX COURT
DAVID K. AND ELIZABETH SIMPSON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 191-02. Filed May 28, 2003.
Kevin G. Staker, for petitioners.
Linette B. Angelastro, for respondent.
MEMORANDUM OPINION
GOEKE, Judge: Respondent determined a deficiency in
petitioners’ 1998 Federal income tax of $879,060. The sole issue
for decision is whether a lump-sum amount received in exchange
for the assignment of the right to receive a portion of certain
future annual lottery payments is ordinary income or capital
gain.
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