Regan v. Commissioner
United States Tax Court
During the years in issue, petitioner was a full-time gambler who gambled solely for his own account. Held, petitioner's gambling activities constituted a trade or business within the meaning of secs. 62(1) and 162(a), I.R.C. 1954. Commissioner v. Groetzinger,480 U.S. , 107 S.Ct. 980 (1987), followed.
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During the years in issue, petitioner was a full-time gambler who gambled solely for his own account. Held, petitioner's gambling activities constituted a trade or business within the meaning of secs. 62(1) and 162(a), I.R.C. 1954. Commissioner v. Groetzinger,480 U.S. , 107 S.Ct. 980 (1987), followed. Consequently, petitioner is not subject to the alternative minimum tax under sec. 55, I.R.C. 1954. Held further, petitioner is not entitled to deduct claimed expenses for meals, lodging, and commissions. Held further, petitioner is liable for an addition to tax pursuant to sec. 6651(a)(1),…
1Opinion of the Court
PATRICK S. REGAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Regan v. Commissioner
Docket No. 41207-84.
United States Tax Court
T.C. Memo 1987-512; 1987 Tax Ct. Memo LEXIS 508; 54 T.C.M. (CCH) 846; T.C.M. (RIA) 87512;
September 30, 1987.
During the years in issue, petitioner was a full-time gambler who gambled solely for his own account.
Held, petitioner's gambling activities constituted a trade or business within the meaning of secs. 62(1) and 162(a), I.R.C. 1954. Commissioner v. Groetzinger,480 U.S. , 107 S.Ct. 980 (1987), followed. Consequently, petitioner is not subject to the…
2Cases cited9 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Commissioner v. GroetzingerSupreme Court of the United States · 1987
- Kroll v. CommissionerUnited States Tax Court · 1968
- Daly v. CommissionerUnited States Tax Court · 1979
4 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Edward W. And Leona J. Andrews v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1991
- Andrews v. CommissionerUnited States Tax Court · 1990
- O'Rourke v. CommissionerUnited States Tax Court · 1990