Tschetschot v. Comm'r
United States Tax Court
R disallowed losses in excess of Ps' winnings from gambling and determined both a deficiency and a penalty for substantial understatement for 2000. After conceding that H's net gambling losses were not properly deductible, Ps argued that, as a professional tournament poker player, W's net losses should be treated the same as those of any other professional sport participants. Held: W's net gambling losses are not exempt from the limitations of sec. 165(d), I.R.C.
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R disallowed losses in excess of Ps' winnings from gambling and determined both a deficiency and a penalty for substantial understatement for 2000. After conceding that H's net gambling losses were not properly deductible, Ps argued that, as a professional tournament poker player, W's net losses should be treated the same as those of any other professional sport participants. Held: W's net gambling losses are not exempt from the limitations of sec. 165(d), I.R.C. Held, further: We leave for the parties to determine as part of their computations under Rule 155, Tax Court Rules of Practice and…
1Opinion of the Court
GEORGE E. AND GLORIA TSCHETSCHOT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Tschetschot v. Comm'r
No. 9498-03
United States Tax Court
T.C. Memo 2007-38; 2007 Tax Ct. Memo LEXIS 37; 93 T.C.M. (CCH) 914;
February 20, 2007, Filed
R disallowed losses in excess of Ps' winnings from gambling and
determined both a deficiency and a penalty for substantial
understatement for 2000. After conceding that H's net gambling
losses were not properly deductible, Ps argued that, as a
professional tournament poker player, W's net losses should be
treated the same as those of any other professional sport
pa…
2Cases cited10 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- Carmichael v. Southern Coal & Coke Co.Supreme Court of the United States · 1937
- Steward MacHine Co. v. DavisSupreme Court of the United States · 1937
- William W. Boyd and Ruth G. Boyd v. United StatesCourt of Appeals for the Ninth Circuit · 1985
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