Legal Opinion
Womack v. Commissioner of IRS
Court of Appeals for the Eleventh Circuit
Decided December 19, 2007No. 07-11568, 07-11569PublishedCited by 8 opinions
1Opinion of the Court
MARTIN, District Judge:
This is an appeal by Florida State Lottery winners from the United States Tax Court’s decision that proceeds from the sale of the rights to future installment payments from lottery winnings (“Lottery Rights”) are taxable as ordinary income, rather than at the lower tax rate applied to the sale of a long term capital asset. The Tax Court specifically held that Lottery Rights are not capital assets as defined in 26 U.S.C. § 1221 (“Section 1221”), under the judicially established substitute for ordinary income doctrine. We affirm.
I. Background
Roland Womack won a portion of…
2Cases cited26 opinions
- Connecticut National Bank v. GermainSupreme Court of the United States · 1992
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Crane v. CommissionerSupreme Court of the United States · 1947
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Commissioner v. GroetzingerSupreme Court of the United States · 1987
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3Cited by8 opinions
- Freda v. COMMISSIONER OF INTERNAL REVENUECourt of Appeals for the Seventh Circuit · 2011
- Principal Life Insurance Company and Subsidiaries v. United StatesUnited States Court of Federal Claims · 2014
- Philip Long v. Commissioner of IRSCourt of Appeals for the Eleventh Circuit · 2014
- Tempel v. Comm'rUnited States Tax Court · 2011
- Cessna v. Comm'rUnited States Tax Court · 2009
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