T.C. Memo. 2004-216
UNITED STATES TAX COURT
GEORGE AND ANGELINE LATTERA, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4269-03. Filed September 23, 2004.
Mark E. Cedrone, for petitioners.
Carol Lynn E. Moran, for respondent.
MEMORANDUM OPINION
VASQUEZ, Judge: Respondent determined a deficiency of
$660,784 in petitioners’ 1999 Federal income tax.1 The sole
issue for decision is whether a lump-sum payment received in
exchange for the assignment of the right to receive future annual
lottery payments is ordinary income or capital gain.
1 All amounts are rounded to the nearest dollar.
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