Roland and Marie Womack - Page 5

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          their Forms 1040, U.S. Individual Income Tax Return.  On their              
          Form 1040 for 2000, the Womacks reported, on Schedule D, Capital            
          Gains and Losses, the $1.328 million received from Singer as                
          long-term capital gain from the sale of a capital asset.                    
               Anastasios and Maria Spiridakos-–The Spiridakoses resided in           
          Clearwater, Florida, at the time their petition was filed.  On or           
          about January 6, 1990, Maria Spiridakos won a $6.24 million prize           
          from the Florida State Lottery.  Consequently, she became                   
          entitled to receive 20 annual $312,000 payments, less mandatory             
          Federal withholding tax, from the Florida State Lottery.  The               
          first payment was scheduled for March 7, 1990, and 19 subsequent            
          installments were to be made on February 15 of each successive              
          year.  Mrs. Spiridakos paid $1 to purchase her lottery ticket,              
          which entitled her to participate in the biweekly Florida State             
          Lottery drawing.  The selection of the number on her lottery                
          ticket entitled her to a share of that drawing’s jackpot.                   
               The Florida State Lottery did not offer winners the option             
          of a lump-sum payment at the time Mrs. Spiridakos won the                   
          lottery.  Under Florida law, Mrs. Spiridakos was required to                
          obtain the approval of the Circuit Court of the Second Judicial             
          Circuit, in and for Leon County, Florida, to transfer her right             
          to receive future lottery winnings.                                         
               On or about July 28, 1999, Mrs. Spiridakos entered into an             
          agreement with Singer to sell and assign all of her remaining               

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