Robert Libutti - Page 1

                                 T.C. Memo. 1996-108                                  


                               UNITED STATES TAX COURT                                


                            ROBERT LIBUTTI, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 1042-93.           Filed March 7, 1996.                     



                    P gambled at T, a casino in Atlantic City, New                    
               Jersey, and incurred losses of $4,139,100 in 1987,                     
               $3,080,050 in 1988, and $1,215,900 in 1989.  Aside from                
               these losses, but as an enticement to frequent T, P                    
               received from T "complimentary" goods and services                     
               (comps) totaling $443,278 in 1987, $974,992 in 1988,                   
               and $1,126,856 in 1989.  On his Federal income tax                     
               returns, P included these comps in his gross income and                
               relied on sec. 165(d), I.R.C., to deduct from his gross                
               income an equal amount of his gambling losses.  Held:                  
               Sec. 165(d), I.R.C., allows him to deduct his gambling                 
               losses to the extent of the comps.                                     

               Bernard Wishnia, for petitioner.                                       
               Daniel K. O'Brien, for respondent.                                     





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