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PETER U. v. COMMISSIONER

Docket No. 6668-00.

85 T.C.M. 1039 (2003)

T.C. Memo. 2003-81

Peter U. and Mary M. Boehme v. Commissioner.

United States Tax Court.

Filed March 20, 2003.

Attorney(s) appearing for the Case

Peter U. Boehme and Mary M. Boehme, pro sese.

Ronald T. Jordan, for the respondent.

MEMORANDUM OPINION

HALPERN, Judge:

By notice of deficiency dated March 31, 2000, respondent determined deficiencies in petitioners' Federal income tax for 1995 and 1996 (the audit years) in the amounts of $2,985 and $140,857, respectively. After concessions, the issues remaining for decision are (1) whether $400,000 received by petitioner Mary M. Boehme in 1996 in exchange for her right to receive certain future annual lottery payments is ordinary income...

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