MEMORANDUM OPINION
COHEN, Judge:
Respondent determined a deficiency of $1,310,766 in petitioner's Federal income tax for 2000. The deficiency was attributable to respondent's recharacterizing the lump-sum proceeds received by petitioner for the sale of rights acquired from the New York State lottery as ordinary income instead of capital gain. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year...
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