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ABEID v. COMMISSIONER

Docket No. 10441-02.

122 T.C. 404 (2004)

122 T.C. No. 24

ISMAT M. ABEID, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 29, 2004.

Attorney(s) appearing for the Case

Donald L. Feurzeig, for petitioner.

Paul R. Zamolo and Rebecca Duewer, for respondent.

OPINION

GALE, Judge:

This case is before us on the parties' crossmotions for summary judgment under Rule 121.1 The issue for decision is whether certain payments received by petitioner from a lottery operated by the State of California (California State Lottery) are exempt from U.S. taxation pursuant to the Income Tax Convention, Nov. 20, 1975, U.S.-Isr., Hein's No. KAV 971 (U.S.-Israel Income Tax Treaty or treaty).

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