Roland and Marie Womack - Page 3

                                        - 3 -                                         
          Petitioners                     Year         Deficiency                     
               Roland & Marie Womack    2000         $235,852                         
               Anastasios & Maria                                                     
          Spiridakos                    2000         1425,678                         
               1 For the Spiridakoses’ 2000 tax year, respondent also                 
          determined that because of their failure to timely pay the amount           
          shown as tax on the return, they were liable for an addition to             
          tax under sec. 6651(a)(2), but the amount was left for                      
          computation at a later date.                                                
               All section references are to the Internal Revenue Code,               
          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure, unless otherwise indicated.                                  

               Roland and Marie Womack--The Womacks resided in Hilliard,              
          Florida, at the time their petition was filed.  On or about                 
          January 20, 1996, Roland Womack won a portion of an $8 million              
          prize from the Florida State Lottery.  Consequently, he became              
          entitled to receive 20 annual $150,000 payments, less mandatory             
          Federal withholding tax, from the Florida State Lottery.  The               
          first payment was scheduled for January 20, 1996, and 19                    
          subsequent installments were to be made on February 15 of each              
          successive year.  Mr. Womack paid $1 to purchase his lottery                
          ticket, which entitled him to participate in the biweekly Florida           
          State Lottery drawing.  The selection of the number on his                  
          lottery ticket entitled him to a share of that drawing’s jackpot.           

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Last modified: May 25, 2011