George and Angeline Lattera - Page 1

                                 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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