Schooler v. Commissioner
United States Tax Court
Held, P, who kept no record of either winnings or losses from racetrack betting, failed to establish that his losses exceeded his unreported income from wagering, and therefore, he was not entitled to a deduction for his claimed losses.
1Opinion of the Court
Simpson, Judge:
The Commissioner determined a deficiency of $5,291 in the petitioners’ Federal income taxes for 1973. The sole issue remaining for decision is whether Mr. Schooler has substantiated wagering losses in excess of his unreported gains from wagering transactions.
FINDINGS OF FACT
Some of the facts have been stipulated, and those facts are so found.
The petitioners, Fred Schooler and Carolyn J. Schooler, were husband and wife and resided in Scottsdale, Ariz., at the time of filing their petition in this case. They filed a joint Federal income tax return for the taxable year 1973 with…
2Cases cited11 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Sanford v. CommissionerUnited States Tax Court · 1968
- William F. Sanford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
- Roberts v. CommissionerUnited States Tax Court · 1974
- Green v. CommissionerUnited States Tax Court · 1976
6 more not listed; retrieve them via the Exa API.
3Cited by41 opinions
- Zielonka v. CommissionerUnited States Tax Court · 1997
- LaPlante v. Comm'rUnited States Tax Court · 2009
- Cooper v. CommissionerUnited States Tax Court · 1987
- Doffin v. CommissionerUnited States Tax Court · 1991
- Free-Pacheco v. United StatesUnited States Court of Federal Claims · 2014
36 more not listed; retrieve them via the Exa API.