Legal Opinion

Groetzinger v. Commissioner

United States Tax Court

Decided May 24, 1984No. Docket No. 2028-82PublishedCited by 42 opinions

Held, based on all the relevant facts in the record, taxpayer, a full-time gambler for his own account, was in the trade or business of gambling. Held, further, taxpayer's gambling losses, to the extent of his gambling gains at least, were not items of tax preference for purposes of computing the minimum tax under sec. 56, I.R.C. 1954, in effect for 1978.

1Opinion of the Court

Drennen, Judge:

Respondent determined a deficiency of $2,521.89 in petitioner’s Federal income tax for the year 1978. The issue for decision is whether petitioner was in the trade or business of gambling during 1978. Resolution of this issue determines whether petitioner is subject to the minimum tax on items of tax preference under section 56.1

FINDINGS OF FACT

Some of the facts have been stipulated and are so found. The stipulation of facts and exhibits attached thereto are incorporated herein by this reference.

Petitioner Robert P. Groetzinger resided in Peoria, Ill., at the time he filed his…

2Cases cited34 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. Snow v. CommissionerSupreme Court of the United States · 1974
  5. Lawrence v. CommissionerUnited States Tax Court · 1957

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

3Cited by42 opinions

  1. Commissioner v. GroetzingerSupreme Court of the United States · 1987
  2. Bokum v. CommissionerUnited States Tax Court · 1990
  3. Laureys v. CommissionerUnited States Tax Court · 1989
  4. Green v. Comm'rUnited States Tax Court · 1984
  5. King v. CommissionerUnited States Tax Court · 1987

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

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