Estate of Paul C. Gribauskas, Deceased, Roy L. Gribauskas, Co-Executor, Carol Beauparlant, Co-Executor v. Commissioner of Internal Revenue

VAN GRAAFEILAND, Senior Circuit Judge.

This appeal concerns the valuation, for estate tax purposes, of a decedent’s Connecticut Lotto prize. The Tax Court (Nims, J.) held that the prize must be valued pursuant to the actuarial tables prescribed under Internal Revenue Code § 7520. For the reasons that follow, we reverse and remand.

The decedent, Paul Gribauskas, and his wife won a $15,807,306.60 Connecticut Lotto prize in late 1992, to be paid out in twenty annual installments of $790,365.34. Following disbursement of the first installment, Gribauskas and his wife divorced. Thereafter, each was…