Clifford F. Mack and Helen L. Mack v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
1Opinion of the Court
O’SULLIVAN, Senior Circuit Judge.
This cause is before the Court on the appeal of Clifford F. Mack and his wife from a judgment of the Tax Court which, for the tax year of 1964, reduced his claim of wagering losses from an asserted $27,200 to $14,000. As provided in 26 U.S.C. § 165(d), a taxpayer may claim deduction for wagering losses “only to the extent of the gains from such transactions.” Appellants also challenge the propriety of a 5% negligence penalty imposed upon the amount of the appellants’ underpayment of income tax for the year 1964. This is provided by 26 U.S.C. § 6653(a). The…
2Cases cited6 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
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- Burnet v. HoustonSupreme Court of the United States · 1931
- Daniel F. Donovan v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1966
- Peter J. And Penny v. Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
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