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.