Julie C. Nichols, n.k.a. Julie C. Amrein - Page 2

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               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 a                     





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