Mayo v. Comm'r
United States Tax Court
P-H was engaged in the trade or business of gambling on horse races during 2001. Ps attached a Schedule C, Profit or Loss From Business, to their 2001 Federal income tax return, on which they reported the results of P-H's gambling business, including gross receipts of $120,463 and expenses of $142,728, consisting of $131,760 for wagers placed and $10,968 in expenses incurred in connection with the conduct of the gambling business.
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P-H was engaged in the trade or business of gambling on horse races during 2001. Ps attached a Schedule C, Profit or Loss From Business, to their 2001 Federal income tax return, on which they reported the results of P-H's gambling business, including gross receipts of $120,463 and expenses of $142,728, consisting of $131,760 for wagers placed and $10,968 in expenses incurred in connection with the conduct of the gambling business. Ps deducted the excess of the Schedule C expenses over gross receipts, $22,265, as a business loss against their other income. R issued a notice of deficiency…
1Opinion of the Court
Gale, Judge:
Respondent determined a deficiency of $9,732 in Federal income tax and an accuracy-related penalty under section 6662(a) and (b)(2)1 of $1,387 with respect to petitioners’ 2001 taxable year.2 Respondent subsequently conceded that petitioner Ronald Andrew Mayo (petitioner)3 was in the trade or business of gambling during 2001 and allowed petitioner’s gambling expenses (which totaled $142,728) to be deducted as trade or business expenses to the extent of his gross receipts from gambling ($120,463). The foregoing concessions resulted in a reduced deficiency and accuracy-related…
2Cases cited21 opinions
- Crane v. CommissionerSupreme Court of the United States · 1947
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Commissioner v. GroetzingerSupreme Court of the United States · 1987
- Commissioner v. SullivanSupreme Court of the United States · 1958
- Di Santo v. PennsylvaniaSupreme Court of the United States · 1927
16 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Lakhani v. Comm'rUnited States Tax Court · 2014
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- Boneparte v. Comm'rUnited States Tax Court · 2017
- Boneparte v. Comm'rUnited States Tax Court · 2015
- Douglas Zierdt v. CommissionerUnited States Tax Court · 2014
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