United States v. J. Michael Maginnis Janet Y. Maginnis

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• concluding that a sale of an entire interest in a lottery winning is \not a persuasive reason to treat the sale of that right as a capital gain.\
• noting that the lottery winner assigned his right to receive all his remaining lottery payments
• holding that the amount that the taxpayer received in exchange for the taxpayer's assignment to a third party of his right to receive certain future annual lottery payments is ordinary income under the \substitute for ordinary income\ doctrine
• holding “that a transaction in which a taxpayer sells his entire interest in an underlying asset without retaining any property right does not automatically prevent application of the substitute for ordinary income doctrine” (emphasis in original)
• holding “that a transaction in which a taxpayer sells his entire interest in an underlying asset without retaining any property right does not automatically prevent application of the substitute for ordinary income doctrine” (emphasis in original)
• applying doctrine where there has been no underlying investment of capital and where sale of asset did not reflect accretion in value over cost of underlying asset, but acknowledging the two factors would not be dispositive in every case

Source: CourtListener parenthetical corpus (CC0).