Legal Opinion
Robert P. Groetzinger v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
Decided August 21, 1985No. 84-2507PublishedCited by 45 opinions
1Opinion of the Court
CUMMINGS, Chief Judge.
The sole issue presented in this appeal is whether the Tax Court erred in holding that the taxpayer’s gambling activities constituted a “trade or business” for purposes of Section 62(1) of the Internal Revenue Code, 26 U.S.C. § 62(1). The Commissioner asserts that the taxpayer’s failure to hold himself out to others as offering goods or services precludes characterization of his activities as a trade or business. We disagree and affirm the Tax Court decision.
I
The significance of the Tax Court’s holding that the activities of the taxpayer, Robert P. Groetzinger,…
2Cases cited23 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Higgins v. CommissionerSupreme Court of the United States · 1941
- United States v. GeneresSupreme Court of the United States · 1972
- Snow v. CommissionerSupreme Court of the United States · 1974
- John M. Trent and Lisa M. Trent v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
18 more not listed; retrieve them via the Exa API.
3Cited by45 opinions
- Commissioner v. GroetzingerSupreme Court of the United States · 1987
- Bokum v. CommissionerUnited States Tax Court · 1990
- Laureys v. CommissionerUnited States Tax Court · 1989
- J.R. Betson, Jr. And Joan Sue Betson v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1986
- Central States, Southeast and Southwest Areas Pension Fund, a Pension Trust, and Howard McDougall Trustee v. Gary L. White and Inge T. WhiteCourt of Appeals for the Seventh Circuit · 2001
40 more not listed; retrieve them via the Exa API.