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Income Tax Keyed to Graetz
Lattera v. Commissioner
Citation:437 F. 3d 399 (3rd Cir. 2006)
In 1991, the Latteras turned in a one-dollar lottery ticket for a prize of nearly $9.5m payable over 26 annual installments. In 1999, the couple sold the right to the remaining 17 lottery payments in exchange for a $3.3m lump sum. Petitioners reported this sale as a taxable gain. The Commissioner of Internal Revenue asserted a deficiency, finding that the lump sum was taxable as ordinary income.
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