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meaning of the statutory text. The comps from Trump increased
petitioner’s wealth, and they were derived out of his betting
transactions at the Casino. The fact that petitioner’s receipt
of the comps bore a close nexus to his gambling transactions at
the Casino cannot be denied. Petitioner would not have received
the comps from Trump but for the fact that he gambled extensively
at the Casino. Although petitioner's receipt of the comps did
not directly hinge on the success or failure of his wagers, he
received the comps incident to his direct participation in
wagering transactions. The relationship between petitioner’s
comps and his wagering is close, direct, evident, and strong.
The comps are sufficiently related to his gambling losses for
purposes of section 165(d). We hold that petitioner’s comps are
“gains from * * * [wagering] transactions” under section 165(d).
We recognize that the term "gains from * * * [wagering]
transactions" has sometimes been equated with the term "gambling
winnings". See Commissioner v. Groetzinger, 480 U.S. 23, 37
(1987) (White, J., dissenting) (full-time gambler may deduct
gambling losses "to the extent of gambling winnings" in computing
adjusted gross income); Collins v. Commissioner, 3 F.3d 625, 631
(2d Cir. 1993) (section 165(d) "only allows gambling losses to
offset gambling winnings"), affg. T.C. Memo. 1992-478. Our
current holding is not in conflict with these opinions. We agree
with Justice White and the Court of Appeals for the Second
Circuit that “gains from * * * [wagering] transactions” include
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