Legal Opinion

Shiraz Noormohamed Lakhani v. Commissioner

United States Tax Court

Decided March 11, 2014No. 21212-10, 24563-11Published

1Opinion of the Court

142 T.C. No. 8

UNITED STATES TAX COURT SHIRAZ NOORMOHAMED LAKHANI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent SHIRAZ LAKHANI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 21212-10, 24563-11.1 Filed March 11, 2014. For 2005-09, P, a professional gambler who bet on horse races, deducted his net wagering losses (either incurred during the year or carried over from prior years) in contravention of I.R.C. sec. 165(d). R disallowed those deductions and imposed an I.R.C. sec. 6662(a) accuracy-related penalty for all years. P argues (1) he is entitled to…

2Cases cited14 opinions

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
  3. Carmichael v. Southern Coal & Coke Co.Supreme Court of the United States · 1937
  4. Jonson v. Comm'rUnited States Tax Court · 2002
  5. Jonson v. CommissionerCourt of Appeals for the Tenth Circuit · 2003

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