Legal Opinion
James F. and Dorothy A. Davis v. Commissioner
United States Tax Court
Decided July 3, 2002No. 6389-01Unknown
1Opinion of the Court
119 T.C. No. 1
UNITED STATES TAX COURT JAMES F. DAVIS AND DOROTHY A. DAVIS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6389-01. Filed July 3, 2002. Ps assigned to S their right to receive a portion of each of certain future annual lottery payments in exchange for a lump-sum payment to them by S of $1,040,000. Held: S paid Ps a lump-sum amount for the right to receive certain future ordinary income. Held, further, Ps’ right to receive certain future annual lottery payments does not constitute a capital asset within the meaning of sec. 1221, I.R.C. Held, further, the…
2Cases cited16 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Hort v. CommissionerSupreme Court of the United States · 1941
- Commissioner v. Gillette Motor Transport, Inc.Supreme Court of the United States · 1960
- Rybak v. CommissionerUnited States Tax Court · 1988
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