Dickerson v. Comr., T.C. Memo. 2012-60

(petitioner received lottery ticket as tip while working as waitress in Alabama (state which did not have lottery at the time); petitioner formed S corporation with family members to receive lottery proceeds; proceeds received, but no Form 709 filed to report gift to other family members; IRS asserted gift tax deficiency of $771,570 plus interest; court upholds IRS deficiency determination - petitioner could not prove existence of contract to share lottery proceeds, and such contract would have been illegal under state law).