Rosa Shackleford, Personal Representative of the Estate of Thomas J. Shackleford, Deceased v. United States

THOMAS, Circuit Judge:

This appeal presents the question of whether a statutory anti-assignment restriction on lottery payments justifies departure from the Department of Treasury’s annuity tables when determining the asset’s present value in calculating estate tax. Under the circumstances of this case, we conclude that it does and affirm the judgment of the district court.

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Fran Lebowitz may have rightly observed that a person has the same chance of winning the lottery whether one plays or not. However, contrary to Steve Martin’s early comedy routine, 1 the probability of tax imposition on the…