Legal Opinion
Jombo v. Commissioner of Internal Revenue Service
Court of Appeals for the D.C. Circuit
Decided February 22, 2005No. 03-1355PublishedCited by 7 opinions
1Opinion of the Court
Opinion for the Court filed by Circuit Judge TATEL.
TATEL, Circuit Judge.
Does a taxpayer who wins a lottery in one year but receives installment payments over the next twenty years constructively receive his entire winnings in the first year, exempting them from federal taxation in later years? The Tax Court answered no, and we agree.
I
In 1989, appellant Augustin Bolsover Jombo was employed as a clerk at Nigeria’s New York Consulate. After purchasing twelve one-dollar lottery tickets, he hit the jackpot, winning a grand total of $26 million. Under then-existing New York State Lottery (“NYSL”)…
2Cases cited8 opinions
- Andantech L.L.C. v. CommissionerCourt of Appeals for the D.C. Circuit · 2003
- Investment Annuity, Inc. v. W. Michael Blumenthal as Secretary of the Treasury of the United StatesCourt of Appeals for the D.C. Circuit · 1979
- Cleo Beatrice Baxter and Albert N. Baxter v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1987
- United States v. J. Michael Maginnis Janet Y. MaginnisCourt of Appeals for the Ninth Circuit · 2004
- Childs v. CommissionerUnited States Tax Court · 1994
3 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- United States v. Raymond P. NovakCourt of Appeals for the Ninth Circuit · 2007
- Commissioner v. SimmonsCourt of Appeals for the D.C. Circuit · 2011
- Barnes v. Commissioner of Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 2013
- Woody v. CommissionerCourt of Appeals for the D.C. Circuit · 2010
- Liljeberg v. Comm'r of Internal RevenueCourt of Appeals for the D.C. Circuit · 2018
2 more not listed; retrieve them via the Exa API.