United States Fifth Circuit

The Tax Court is affirmed where it properly concluded that a non-transferable lottery prize payable in seventeen annual installments is a private annuity that must be valued, for estate tax purposes, in accordance with 26 U.S.C. section 7520.

Appellate Information

• Decided 11/13/2003
• Published 11/13/2003

Judges

• DUHÉ, Circuit Judge:, Before DAVIS, SMITH and DUHÉ, Circuit Judges.

Court

• United States Fifth Circuit

Counsel

• For Appellant:
  
• John W. Porter (argued), Stephanie Loomis-Price, Baker Botts, Houston, TX, Robert Allen Helms, Edwin Walker Arenson, Arenson & Spears, Austin, TX, for Petitioner-Appellant.


• For Appellees:
  
• Annette Marie Wietecha, Jonathan S. Cohen (argued), U.S. Dept. of Justice, Tax Div., Washington, DC, for Respondent-Appellee.