CLOPTON v. COMMISSIONER

Dkt. No. 4627-03.

87 T.C.M. 1217 (2004)

T.C. Memo. 2004-95

Alden L. Clopton and Yolanda Y. Clopton v. Commissioner.

United States Tax Court.

Filed April 6, 2004.


Attorney(s) appearing for the Case

Frank Sommerville, for petitioners.

W. Lance Stodghill, for respondent.


GOEKE, Judge:

Respondent determined a deficiency in petitioners' 1999 Federal income tax of $221,269.96. The sole issue for decision is whether a lump-sum amount received in exchange for an interest in a trust holding the right to receive future annual lottery payments is ordinary income or capital gain. We hold under the substitute for ordinary income doctrine that the lump-sum amount is ordinary income.

Background

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