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facts presented herein, we hold that the expenses incurred by
petitioner in order to attend and participate in the "Wheel of
Fortune" game show are at best expenses, deductible as a
miscellaneous itemized deduction under section 67, rather than
wagering losses under section 165(d). In so holding, we reject
petitioners' contention that the expenses in issue are tantamount
to a bet or wager. Unlike a wager or bet, petitioner incurred
the expenses in question in exchange for specific goods and
services, such as transportation, meals, and lodging. Further,
we doubt that Congress ever intended to allow casual gamblers to
treat expenses for transportation, meals, and lodging as anything
other than either miscellaneous itemized deductions or
nondeductible personal expenses. Consequently, we shall deny
petitioners' Motion for Summary Judgment and grant respondent's
cross motion.
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