Edman and Debbie Kay Hackworth - Page 6

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               Petitioners attached three Schedules C, Profit or Loss From            
          Business, to their 1999 return.  The first two Schedules C                  
          related to businesses operated by Mrs. Hackworth.  The third                
          Schedule C related to petitioner’s gambling activities.  On his             
          Schedule C, petitioner reported gross receipts of $178,236 from             
          his gambling activities, which were referred to as “services” on            
          this form.  Petitioner also deducted $152,016 for “legal and                
          professional services” on this form.  This deduction was taken              
          for the cash that petitioner forfeited to the State of South                
          Carolina as a result of his violation of South Carolina’s                   
          gambling laws.                                                              
               In the statutory notice of deficiency sent to petitioners,             
          in addition to the adjustments no longer contested, the IRS                 
          disallowed the $152,016 deduction claimed on petitioner’s                   
          Schedule C.  The IRS determined that petitioners had not                    
          established that any amount of this claimed deduction represented           
          a deductible expense, was an ordinary and necessary business                
          expense, or was expended for the purpose designated.                        
          Accordingly, the IRS increased petitioners’ taxable income for              
          1999 by $152,016.                                                           
                                       OPINION                                        
               Petitioners seek a deduction for the cash that petitioner              
          voluntarily forfeited to the State of South Carolina under                  
          section 16-19-80 (“Forfeiture of wagers”) of the Code of Laws of            






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