Roland and Marie Womack - Page 19

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         unpersuaded that those statutes and definitions have any                     
         relevance to the question we consider.  In addition, even if they            
         are analogous, petitioners’ intent is to show that such                      
         definitions support their argument that lottery rights are                   
         capital assets within the meaning of section 1221.  As we have               
         already observed, the substitute for ordinary income doctrine                
         applies to the lottery rights petitioners sold irrespective of               
         whether they may be comparable to the categories defined in                  
         section 1221 as capital assets.  See also United States v.                   
         Maginnis, 356 F.3d at 1187 n.10.                                             
              We have considered petitioners’ remaining arguments.                    
         Because of the extensive precedent to the contrary, there is no              
         need for any additional discussion in this opinion.                          
              To reflect the foregoing,                                               

                                       Decisions will be entered for                  
                                  respondent in docket No. 13434-03 and               
                                  under Rule 155 in docket No. 19829-03.              

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