Legal Opinion

Tschetschot v. Comm'r

United States Tax Court

Decided February 20, 2007No. 9498-03UnpublishedCited by 8 opinions

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

  1. Welch v. HelveringSupreme Court of the United States · 1933
  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. Steward MacHine Co. v. DavisSupreme Court of the United States · 1937
  5. William W. Boyd and Ruth G. Boyd v. United StatesCourt of Appeals for the Ninth Circuit · 1985

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

3Cited by8 opinions

  1. Mayo v. Comm'rUnited States Tax Court · 2011
  2. Lakhani v. Comm'rUnited States Tax Court · 2014
  3. California Attorney General Opinion 23-1001, California Attorney General Reports2025
  4. Lakhani v. Comm'rUnited States Tax Court · 2014
  5. Mayo v. Comm'rUnited States Tax Court · 2011

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

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