Offutt v. Commissioner
United States Tax Court
Wagering losses in excess of wagering gains held not available to offset other income nor to create net operating loss carry-overs or carry-backs, notwithstanding legality and regularity of petitioner's wagering business. Section 23 (h), Internal Revenue Code.
1Opinion of the Court
OPINION.
Offer, Judges
It would be easy to extend the scope of. tliis controversy to take in a wide range of subject matter. As presented, however, it is narrowly limited and we propose to restrict our consideration accordingly.
The .single issue, with which we are required, to deal is -in essence whether a professional gambler may deduct gambling losses exceeding gambling gains, although concededly another taxpayer not regularly engaged in gambling as a business, hut undertaking gambling ventures for profit, could not do so.
We are not here confronted with the problem of whether the specific…
2Cases cited3 opinions
- Cohen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1949
- Skeeles v. United StatesUnited States Court of Claims · 1951
- Humphrey v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1947
3Cited by32 opinions
- Gordon v. CommissionerUnited States Tax Court · 1974
- George Winkler v. United StatesCourt of Appeals for the First Circuit · 1956
- Estate of Maurice G. Todisco, Framingham Trust Company v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1985
- Irving Nitzberg and Ida Nitzberg, and Sid Miller and Helen Miller v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1978
- Mayo v. Comm'rUnited States Tax Court · 2011
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