Lattera v. Commissioner

437 F.3d 399 (2006)

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Lattera v. Commissioner

United States Court of Appeals for the Third Circuit
437 F.3d 399 (2006)

SC

Facts

George and Angeline Lattera (plaintiffs) won the lottery. Their winnings of over $9 million were to be paid in annual installments for 26 years. With 17 installments remaining, the Latteras chose to sell their rights to the remaining installment payments for a lump-sum payment. The Latteras reported the sale as a sale of a capital asset on their income tax return. The Internal Revenue Service (IRS) (defendant) determined that the income should be ordinary income. The Latteras appealed the decision to federal court. The Latteras acknowledged that each individual installment payment was ordinary income.

Rule of Law

Issue

Holding and Reasoning (Ambro, J.)

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