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LATTERA v. C.I.R.

No. 04-4721.

437 F.3d 399 (2006)

George LATTERA; Angeline Lattera, Appellants v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals, Third Circuit.

Filed February 14, 2006.

Attorney(s) appearing for the Case

Mark E. Cedrone, (Argued), Cedrone & Janove, Philadelphia, PA, for Appellants.

Eileen J. O'Connor, Assistant Attorney General, Regina S. Moriarty, (Argued), Richard Farber, United States Department of Justice, Tax Division, Washington, DC, for Appellee.

Before BARRY and AMBRO, Circuit Judges, and DEBEVOISE, District Judge.

AMBRO, Circuit Judge.

Lottery winners, after receiving several annual installments of their lottery prize, sold for a lump sum the right to their remaining payments. They reported their sale proceeds as capital gains on their tax return, but the Internal Revenue Service (IRS) classified those proceeds as ordinary income. The substitute-for-ordinary-income doctrine holds that lump-sum consideration substituting for something...

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