VALUATION: Section 7520 Applied to Lottery Winnings

The Sixth Circuit in Negron v. U.S., 103 A.F.T.R. 2d 1009-634 reversed 502 F.Supp. 2d 682 (D.C. OH) and held, following the Fifth Circuit in Cook, that lottering winnings should be valued pursuant to section 7520. As the Court noted, “A marketability factor is not necessary to determine the value of a guaranteed income stream…”