Ismat M. Abeid v. Commissioner

122 T.C. No. 24

UNITED STATES TAX COURT ISMAT M. ABEID, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10441-02. Filed June 29, 2004. 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…