Legal Opinion

Green v. Commissioner

United States Tax Court

Decided June 22, 1976No. Docket No. 1785-73Published

Petitioner was a member of a partnership, known as the Raven Club, which conducted a casino-type gambling operation, including dice tables, a roulette wheel, blackjack tables, and slot machines, in Biloxi, Miss., during the taxable years involved. The partnership maintained a daily record showing its net wins or net losses, operational expenses and disbursements, and the balance of the partnership bankroll for each day.

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Petitioner was a member of a partnership, known as the Raven Club, which conducted a casino-type gambling operation, including dice tables, a roulette wheel, blackjack tables, and slot machines, in Biloxi, Miss., during the taxable years involved. The partnership maintained a daily record showing its net wins or net losses, operational expenses and disbursements, and the balance of the partnership bankroll for each day. The originals of these records, together with receipts for expenditures, were delivered monthly to an experienced accountant and former IRS agent, who maintained a journal and…

1Opinion of the Court

Gene P. Green and Louise Green, Petitioners v. Commissioner of Internal Revenue, Respondent

Green v. Commissioner

Docket No. 1785-73

United States Tax Court

66 T.C. 538; 1976 U.S. Tax Ct. LEXIS 85;

June 22, 1976, Filed

Decision will be entered under Rule 155.

Petitioner was a member of a partnership, known as the Raven Club, which conducted a casino-type gambling operation, including dice tables, a roulette wheel, blackjack tables, and slot machines, in Biloxi, Miss., during the taxable years involved. The partnership maintained a daily record showing its net wins or net losses, operational expenses…

2Cases cited22 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  3. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  4. Wickwire v. ReineckeSupreme Court of the United States · 1927
  5. Mitchell v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1941

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