Legal Opinion

Noto v. United States

District Court, D. New Jersey

Decided September 21, 1984No. Civ. A. 83-3952PublishedCited by 13 opinions

1Opinion of the Court

MEMORANDUM OPINION

LACEY, District Judge.

There is only one issue left to be decided in this action: 1 whether the gambling activities of plaintiff Louis Noto 2 during 1978 constitute a “trade or business” within the meaning of Sections 62(1) and 162(a) of the Internal Revenue Code (the Code), 26 U.S.C. §§ 62(1) and 162(a). 3 Plaintiff says that they do and seeks to have his 1978 gambling losses treated as “above the line” deductions, deductible from gross income in arriving at adjusted gross income under Section 62(1). The Government maintains that the losses are not attributable to a trade or…

2Cases cited16 opinions

  1. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  2. Higgins v. CommissionerSupreme Court of the United States · 1941
  3. Whipple v. CommissionerSupreme Court of the United States · 1963
  4. Anna J. McDowell v. Abraham A. Ribicoff, Secretary of Health, Welfare and EducationCourt of Appeals for the Third Circuit · 1961
  5. Commissioner of Internal Revenue v. NubarCourt of Appeals for the Fourth Circuit · 1950

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

3Cited by13 opinions

  1. Commissioner v. GroetzingerSupreme Court of the United States · 1987
  2. Robert P. Groetzinger v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1985
  3. Ross v. AmeriChoice Federal Credit UnionDistrict Court, E.D. Pennsylvania · 2015
  4. Michelman v. Hanil Bank, Ltd. (In Re Jee)United States Bankruptcy Court, C.D. California · 1989
  5. United States v. W.R. Grace & Co.-Conn.District Court, D. New Jersey · 1999

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

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