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petitioner must include $2,800 in gambling winnings in her gross
income for 2003; (2) whether she can use her gambling losses to
offset her gambling winnings; and (3) whether any portion of her
Social Security disability benefits is includable in her gross
income for 2003.2
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
herein by this reference. At the time she filed the petition,
petitioner resided in Raynham, Massachusetts.
During 2003, petitioner attended a driver training program
for Greyhound Lines, Inc. (Greyhound). After completion,
petitioner was employed as a driver for Greyhound. However,
after working only a couple of months, petitioner could no longer
drive due to physical ailments.
During 2003, petitioner was not engaged in the trade or
business of gambling. However, petitioner won two slot machine
1(...continued)
a child tax credit not claimed on petitioner’s 2003 tax return.
2 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure. All
amounts are rounded to the nearest dollar.
While not in issue, the amounts of the child tax credit,
additional child credit, and the earned income credit that
petitioner is entitled to is dependent upon the resolution of the
issues for decision in this case and should be addressed in the
parties’ Rule 155 computations.
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