- 5 - affg. T.C. Memo. 1983-247 (holding that deductions for State taxes attributable to gambling income are limited under section 165(d)); Kochevar v. Commissioner, T.C. Memo. 1995-607 (holding that slot-machine players, even if considered to be in the trade or business of gambling, could deduct gambling losses and expenses, including automatic teller machine charges, office supplies, travel mileage, and meals, only to the extent of their winnings); Valenti v. Commissioner, T.C. Memo. 1994-483 (holding that a deduction for losses incurred in wagering transactions is subject to section 165(d) regardless of the fact that the taxpayer was in the trade or business of gambling); Kozma v. Commissioner, T.C. Memo. 1986-177 (construing the phrase “losses from wagering transactions” as used in section 165(d) to include expenses incurred by a professional gambler for transportation, meals, lodging, admission fees, and office supplies). According to petitioners, the precedent established by the Offutt line of cases should not be followed because the reasoning expressed in those cases is based more upon a prejudicial view towards gamblers and gambling than technical considerations. We disagree with the premise as well as the proposition. We are satisfied that following the precedent established by the above line of cases leads to a result in this case that is supported by the express language of section 165(d) and, although petitioners suggest otherwise, entirely consistent with CongressionalPage: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011