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Womack v. Commissioner

United States Court of Appeals for the Eleventh Circuit
510 F.3d 1295 (2000)


Facts

Roland Womack (plaintiff) was a winner of the Florida State Lottery. Womack’s lottery winnings were payable in 20 annual installments of $150,000. After receiving three years of lottery payments, Womack sold his right to receive the remaining payments for an immediate lump-sum payment. On his federal tax return, Womack reported the lump-sum payment as a capital gain from the sale of a long-term asset. The federal tax commissioner (commissioner) (defendant) issued a deficiency notice against Womack. Womack petitioned the United States Tax Court for a redetermination. The tax court entered judgment in favor of the commissioner. Womack appealed to the United States Court of Appeals for the Eleventh Circuit.

Rule of Law

Issue

Holding and Reasoning (Martin, J.)

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