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WATKINS v. COMMISSIONER

Docket No. 19587-02.

88 T.C.M. 390 (2004)

T.C. Memo. 2004-244

Roger L. Watkins v. Commissioner.

United States Tax Court.

October 26, 2004.

Attorney(s) appearing for the Case

Eric J. Zinn and Gregory W. Berger, for petitioner.

Mary T. Klaasen, for respondent.

MEMORANDUM OPINION

HAINES, Judge:

Respondent determined a $518,463 deficiency in petitioner's Federal income tax for 1998 (year in issue). The sole issue for decision is whether petitioner's receipt of $2,614,744 in exchange for an assignment of a right to receive future lottery installment payments constitutes ordinary income or capital gain during the year in issue.1

Unless...

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