Legal Opinion
George Lattera Angeline Lattera v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided February 14, 2006No. 04-4721PublishedCited by 15 opinions
1Opinion of the Court
AMBRO, Circuit Judge.
Lottery winners, after receiving several annual installments of their lottery prize, sold for a lump sum the right to their remaining payments. They reported their sale proceeds as capital gains on their tax return, but the Internal Revenue Service (IRS) classified those proceeds as ordinary income. The substitute-for-ordinary-income doctrine holds that lump-sum consideration substituting for something that would otherwise be received at a future time as ordinary income should be taxed the same way. We agree with the Commissioner of the IRS that the lump-sum consideration…
2Cases cited19 opinions
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Commissioner v. GroetzingerSupreme Court of the United States · 1987
- Fed. Sec. L. Rep. P 95,614 the Exchange National Bank of Chicago v. Touche Ross & Co.Court of Appeals for the Second Circuit · 1976
- Reves v. Ernst & YoungSupreme Court of the United States · 1990
- Hort v. CommissionerSupreme Court of the United States · 1941
14 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Charles P. Stepnowski v. Commissioner of Internal Revenue Hercules IncorporatedCourt of Appeals for the Third Circuit · 2006
- Tempel v. Comm'rUnited States Tax Court · 2011
- Watkins v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 2006
- Womack v. Commissioner of IRSCourt of Appeals for the Eleventh Circuit · 2007
- Mulcahy, Pauritsch, Salvador & Co. v. CommissionerCourt of Appeals for the Seventh Circuit · 2012
10 more not listed; retrieve them via the Exa API.