- 14 -
was the players who placed the bets. Accord Allen v. United
States, supra.
In conclusion, we hold that petitioner's comps are "gains
from * * * [wagering] transactions" that may be offset by
wagering losses under section 165(d). In so holding, we have
considered all arguments made by respondent with respect to
section 165(d), and, to the extent not addressed above, have
found them to be without merit. In light of our holding, we need
not consider petitioner’s alternative arguments.
To reflect the foregoing,
Decision will be entered
under Rule 155.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
Last modified: May 25, 2011