United States DC Circuit

A taxpayer who wins a lottery in one year, but receives installment payments over the next twenty years, does not constructively receive his entire winnings in the first year and is not exempt from federal taxation in later years.

Appellate Information

• Argued 12/03/2004
• Decided 02/22/2005
• Published 02/22/2005

Judges

• Before:  HENDERSON, TATEL, and ROBERTS, Circuit Judges.

Court

• United States DC Circuit

Counsel

• For Appellant:
  
• Augustin B. Jombo, pro se, argued the cause and filed the briefs for appellant.


• For Appellees:
  
• Karen D. Utiger, Attorney, U.S. Department of Justice, argued the cause for appellee.   With her on the brief were Eileen J. O'Connor, Assistant Attorney General, and Richard Farber, Attorney, U.S. Department of Justice.  Gilbert S. Rothenberg, Attorney, U.S. Department of Justice, entered an appearance.