Legal Opinion

Commissioner v. Groetzinger

Supreme Court of the United States

Decided February 24, 1987No. 85-1226PublishedCited by 482 opinions

1Opinion of the CourtJustice Blackmun

The issue in this case is whether a full-time gambler who makes wagers solely for his own account is engaged in a “trade or business,” within the meaning of §§ 162(a) and 62(1) of the Internal Revenue Code of 1964, as amended, 26 U. S. C. §§ 162(a) and 62(1) (1976 ed. and Supp. V).1 The tax year with which we here are concerned is the calendar year 1978; technically, then, we look to the Code as it read at that time.

I

There is no dispute as to the facts. The critical ones are stipulated. See App. 9. Respondent Robert P. Groet-zinger had worked for 20 years in sales and market research for an…

2Cases cited31 opinions

  1. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  2. Marchetti v. United StatesSupreme Court of the United States · 1968
  3. Helvering v. HorstSupreme Court of the United States · 1940
  4. Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
  5. Higgins v. CommissionerSupreme Court of the United States · 1941

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3Cited by482 opinions

  1. Hotel 71 Mezz Lender LLC v. National Retirement FundCourt of Appeals for the Seventh Circuit · 2015
  2. Bokum v. CommissionerUnited States Tax Court · 1990
  3. Chai v. CommissionerCourt of Appeals for the Second Circuit · 2017
  4. Bernard A. Levin, Phyllis Levin, Alan T. Hrabosky, and Delores Hrabosky v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1987
  5. Westbrook v. CommissionerCourt of Appeals for the Fifth Circuit · 1995

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

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