- 2 - Background The parties submitted this case fully stipulated pursuant to Rule 122.1 The stipulation of facts and the attached exhibits are incorporated herein by this reference. Petitioners, Mr. Simpson and Mrs. Simpson, are husband and wife and resided in Santa Barbara, California, at the time they filed their petition. On April 29, 1992, Mr. Simpson won a California lottery prize of $15,740,000. Under California law at that time, the prize was payable in 20 annual installments of $787,000, with the first installment payable on April 29, 1992, and subsequent installments payable each year on April 29 through the year 2011. On July 20, 1992, Mr. Simpson assigned his California lottery prize to the Simpson Trust.2 On April 20, 1997, Mr. Simpson, in his capacity as trustee of the Simpson Trust, assigned a portion of the lottery prize to Singer Asset Finance Company, LLC (Singer). Under the assignment agreement, all rights to $140,000 of 12 annual lottery payments 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. 2The evidence in the record indicates that Mr. Simpson was the sole trustee of the Simpson Trust and that he took all subsequent actions with respect to the annual lottery payments discussed herein in his capacity as trustee. Petitioners apparently have taken and continue to take the position, which respondent does not dispute, that all income of the Simpson Trust is includable in their income.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011