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DAVID K. v. COMMISSIONER

Docket No. 191-02.

85 T.C.M. 1421 (2003)

T.C. Memo. 2003-155

David K. and Elizabeth Simpson v. Commissioner.

United States Tax Court.

Filed May 28, 2003.

Attorney(s) appearing for the Case

Kevin G. Staker, for the petitioners.

Linette B. Angelastro, for the respondent.

MEMORANDUM OPINION

GOEKE, Judge:

Respondent determined a deficiency in petitioners' 1998 Federal income tax of $879,060. The sole issue for decision is whether a lump-sum amount received in exchange for the assignment of the right to receive a portion of certain future annual lottery payments is ordinary income or capital gain.

Background

The parties submitted this case fully stipulated pursuant to Rule 122.1

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