T.C. Memo. 2004-95
UNITED STATES TAX COURT
ALDEN L. CLOPTON AND YOLANDA Y. CLOPTON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4627-03. Filed April 6, 2004.
Frank Sommerville, for petitioners.
W. Lance Stodghill, for respondent.
MEMORANDUM OPINION
GOEKE, Judge: Respondent determined a deficiency in
petitioners’ 1999 Federal income tax of $221,269.96. The sole
issue for decision is whether a lump-sum amount received in
exchange for an interest in a trust holding the right to receive
future annual lottery payments is ordinary income or capital
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