Davis v. Commissioner
United States Tax Court
119 T.C. 1 (2002)
In 1991, James Davis (plaintiff) won $13,580,000 in the California lottery. Davis’s winnings were payable in 20 annual installments of $679,000 each. In 1997, Davis sold his rights to a portion of the remaining installments in return for a substantially discounted lump sum of $1,040,000. On Davis’s 1997 federal tax return, Davis reported the sale of his rights as the sale of capital assets. The commissioner of internal revenue (commissioner) (defendant) determined that this was not a sale of capital assets, and added $1,040,000 to Davis’s ordinary income for 1997. Davis petitioned the tax court for a redetermination.
Rule of Law
Holding and Reasoning (Chiechi, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 687,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead our student testimonials
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.Learn about our approachRead more about Quimbee
Here's why 687,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 42,900 briefs, keyed to 988 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.