EDWARD D. HAMILTON AND YOLONDA B. HAMILTON - Page 4

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          winnings is includable in an individual taxpayer’s gross income             
          whether he or she is a professional gambler, a part-time gambler,           
          or simply a onetime gambler.  Id.                                           
               Nor do we agree with petitioners’ second argument that their           
          adjusted gross income under section 469(i)(3) does not include              
          their lottery winnings.  For purposes of the income tax                     
          provisions of the Internal Revenue Code, the term “adjusted gross           
          income” is defined by section 62 as gross income less certain               
          enumerated deductions, none of which is relevant here.  While               
          section 469(i)(3)(F) also enumerates certain other adjustments              
          which affect that term for purposes of section 469(i)(3), all of            
          those enumerated adjustments are inapplicable as well.                      
               We conclude that petitioners’ lottery winnings are                     
          includable in their adjusted gross income for purposes of section           
          469(i)(3).  Although petitioners as a third argument essentially            
          invite this Court to apply some principle of equity to arrive at            
          a contrary result, we decline to do so.  This Court is not                  
          authorized to ignore such a clear expression of Congress’ intent            
          as applies here.  Flight Attendants Against UAL Offset v.                   
          Commissioner, 165 F.3d 572, 578 (7th Cir. 1999).                            













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