Legal Opinion

Mayo v. Comm'r

United States Tax Court

Decided January 25, 2011No. Docket No. 15527-03Published

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

RONALD ANDREW MAYO AND LESLIE ARCHER MAYO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Mayo v. Comm'r

Docket No. 15527-03

United States Tax Court

136 T.C. 81; 2011 U.S. Tax Ct. LEXIS 4; 136 T.C. No. 4;

January 25, 2011, Filed

Decision will be entered under Rule 155.

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…

Also in this document: Concurrence.

2Cases cited23 opinions

  1. Crane v. CommissionerSupreme Court of the United States · 1947
  2. Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
  3. Commissioner v. GroetzingerSupreme Court of the United States · 1987
  4. Commissioner v. SullivanSupreme Court of the United States · 1958
  5. Di Santo v. PennsylvaniaSupreme Court of the United States · 1927

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