- 2 - Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue. FINDINGS OF FACT Some of the facts have been stipulated, and the stipulated facts are incorporated in our findings by this reference. Petitioner resided in Washington, Missouri, at the time that she filed her petition. Petitioner married James M. Nichols (Nichols) on November 19, 1988. Petitioner and Nichols separated in March 2000 and were divorced on January 17, 2001. Nichols was a member of a group of 12 individuals who won the Connecticut State Lottery drawing on October 28, 1987. Nichols’s portion of the lottery prize was $756,540, payable over 20 years in annual installments of $37,827. At the time that she married Nichols, petitioner knew that Nichols had won a lottery and received approximately $30,000 per year in lottery proceeds. On August 21, 1997, petitioner executed a Certificate of Marital Status that was to be attached as exhibit “B” to a Lottery Prize Assignment Agreement between Nichols and Woodbridge Sterling Capital, LLC. Petitioner inserted her name, address, and Social Security number on the Certificate of Marital Status and dated it and signed it before a notary public. The Certificate of Marital Status expressly stated: I consent to my spouse entering into the Assignment and furthermore to the application to aPage: Previous 1 2 3 4 5 6 7 8 Next
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