Legal Opinion

Stevens v. Commissioner

United States Tax Court

Decided August 23, 1971No. Docket No. 4363-70PublishedCited by 1 opinion

Petitioners had income in 1966 from Irish Sweepstakes winnings. Held, such income constitutes "wagering income" and is not entitled to the benefit of the averaging provisions in effect during that year. Sec. 1302(b)(3), I.R.C. 1954.

1Opinion of the Court

Tannenwald, Judge:

Respondent determined a deficiency of $28,310.18 in petitioners’ income tax for tbe calendar year 1966. Tbe sole issue before us is whether petitioner Lillian Stevens’ 1966 Irish Hospitals’ Sweepstakes winnings constitute wagering income within tbe meaning of section 1302(b) (3)1 and are therefore excludable from tbe benefits of income averaging provided by section 1301.

FINDINGS OF FACT

Petitioners, husband and wife, bad their legal residence in Chicago, Ill., at the time the petition herein was filed. They filed a joint Federal income tax return for the taxable year 1966…

2Cases cited7 opinions

  1. Douglas Goldman and Evelyn K. Goldman v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1967
  2. Drews v. CommissionerUnited States Tax Court · 1956
  3. Goldman v. CommissionerUnited States Tax Court · 1966
  4. Offutt v. CommissionerUnited States Tax Court · 1951
  5. Skeeles v. United StatesUnited States Court of Claims · 1951

2 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. Stevens v. CommissionerUnited States Tax Court · 1971

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