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whether his gambling activity was his “intended livelihood
source”, Commissioner v. Groetzinger, 480 U.S. at 33, as his
bankroll was described as “cumulative winnings” with no mention
about withdrawals for “livelihood” expenditures. Maintaining a
“bankroll” used exclusively for gambling purposes strongly
suggests that his gambling activity does not constitute a trade
or business. To the extent that petitioner’s betting strategy
remains consistent over the years, a different result might well
be reached.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for petitioner.
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