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commencing April 20, 1997, through and including April 20, 2008,
were assigned to Singer.3 The assignment left the Simpson Trust
with the right to receive future annual lottery payments of
$647,000 through the year 2008. The right to receive the 2009,
2010, and 2011 payments was not assigned.
On June 2, 1998, Mr. Simpson, as trustee of the Simpson
Trust, entered into another assignment agreement with Singer.
Pursuant to this agreement, the right to receive the remaining
$647,000 of 10 annual lottery payments for the years 1999 through
2008 was assigned to Singer in exchange for a lump-sum payment of
$4,485,000.
At all relevant times, the laws of the State of California
precluded a lottery winner from assigning the right to receive
future annual lottery payments without obtaining California
Superior Court approval. On June 26, 1998, the Simpson Trust and
Singer filed with the California Superior Court for the County of
Sacramento (Sacramento County Superior Court) a joint petition
for an order approving voluntary assignment of lottery winnings.
On July 7, 1998, the Sacramento County Superior Court issued an
order approving the assignment.
Singer issued to Mr. Simpson a Form 1099-B, Proceeds From
Broker and Barter Exchange Transactions, for 1998. The Form
3The evidence in the record does not reflect the
consideration paid by Singer under this assignment agreement.
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