Collins
United States Tax Court
In one afternoon in July 1988, P, a ticket seller at a New York Off-Track Betting (OTB) parlor, punched up betting tickets for himself on his computer terminal without paying for them. The tickets, which evidenced P's bets on nine horseraces, had a total face amount of $ 80,280; P's tickets for the last two races resulted in winnings of $ 42,175 and a net loss of $ 38,105 for the day.
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In one afternoon in July 1988, P, a ticket seller at a New York Off-Track Betting (OTB) parlor, punched up betting tickets for himself on his computer terminal without paying for them. The tickets, which evidenced P's bets on nine horseraces, had a total face amount of $ 80,280; P's tickets for the last two races resulted in winnings of $ 42,175 and a net loss of $ 38,105 for the day. P did not remove any cash from his cash drawer, and transferred his winning tickets to OTB when he turned himself in at the end of the day. In October 1988, P pleaded guilty to grand larceny in the third degree.…
1Opinion of the Court
MARK D. COLLINS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Collins
Docket No. 11579-90
United States Tax Court
T.C. Memo 1992-478; 1992 Tax Ct. Memo LEXIS 503; 64 T.C.M. (CCH) 557;
August 24, 1992, Filed
Decision will be entered under Rule 155.
In one afternoon in July 1988, P, a ticket seller at a New York Off-Track Betting (OTB) parlor, punched up betting tickets for himself on his computer terminal without paying for them. The tickets, which evidenced P's bets on nine horseraces, had a total face amount of $ 80,280; P's tickets for the last two races resulted in winnings of $…
2Cases cited30 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Lochner v. New YorkSupreme Court of the United States · 1905
- Neely v. CommissionerUnited States Tax Court · 1985
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
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