Abeid v. Comm'r
United States Tax Court
P, a nonresident alien residing in Israel during 1997, 1998, and 1999 (years in issue), became entitled to 20 annual payments of $ 722,000 each by virtue of a 1992 purchase of a $ 1 ticket that won a lottery sponsored by the State of California. P received a payment of $ 722,000 from the California State Lottery in each of the years in issue. P filed U.S. Federal income tax returns for those years in which he took the position that the payments were not subject to U.S. tax.
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P, a nonresident alien residing in Israel during 1997, 1998, and 1999 (years in issue), became entitled to 20 annual payments of $ 722,000 each by virtue of a 1992 purchase of a $ 1 ticket that won a lottery sponsored by the State of California. P received a payment of $ 722,000 from the California State Lottery in each of the years in issue. P filed U.S. Federal income tax returns for those years in which he took the position that the payments were not subject to U.S. tax. R determined that the payments were subject to U.S. tax under sec. 871(a)(1)(A), I.R.C., resulting in a deficiency for…
1Opinion of the Court
ISMAT M. ABEID, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Abeid v. Comm'r
No. 10441-02
United States Tax Court
122 T.C. 404; 2004 U.S. Tax Ct. LEXIS 24; 122 T.C. No. 24;
June 29, 2004, Filed
Respondent's cross-motion for summary judgment was granted and petitioner's motion for summary judgment was denied.
P, a nonresident alien residing in Israel during 1997,
1998, and 1999 (years in issue), became entitled to 20 annual
payments of $ 722,000 each by virtue of a 1992 purchase of a $ 1
ticket that won a lottery sponsored by the State of California.
P received a payment of $ 722,000 from…
2Cases cited16 opinions
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Florida Peach Corp. v. CommissionerUnited States Tax Court · 1988
- Commissioner v. WemyssSupreme Court of the United States · 1945
- F. L. McClanahan v. United StatesCourt of Appeals for the Fifth Circuit · 1961
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