Shirley B. Prebola n.k.a. Shirley D. Begy v. Commissioner

T.C. Memo. 2005-261

UNITED STATES TAX COURT SHIRLEY B. PREBOLA n.k.a. SHIRLEY D. BEGY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4117-04. Filed November 8, 2005. Gerald W. Dibble, for petitioner. Kevin M. Murphy, for respondent. MEMORANDUM OPINION COHEN, Judge: Respondent determined a deficiency of $1,310,766 in petitioner’s Federal income tax for 2000. The deficiency was attributable to respondent’s recharacterizing the lump-sum proceeds received by petitioner for the sale of rights acquired from the New York State lottery as ordinary income instead of capital…