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is not reviewable by any other court, and this opinion should not
be cited as authority.
Respondent determined a deficiency in petitioner’s Federal
income tax for 2003 of $3,068. Petitioner timely filed a
petition with the Court. The sole issue for decision is whether
petitioner’s gambling activity constituted a trade or business
under section 162 and, consequently, whether he was a
professional gambler in 2003.
Background
Some of the facts have been stipulated, and they are so
found. We incorporate by reference the parties’ stipulation of
facts at trial and accompanying exhibits.
At the time the petition was filed, petitioner resided in
Berwyn, Illinois.
During the taxable year in issue, petitioner was employed
full-time as a building operating engineer in Chicago and earned
approximately $51,840 from his employment in 2003.
In addition to his employment, petitioner spent a good deal
of time playing video poker. It was his only form of gambling.
Petitioner bet an average of $25 on each hand. He began playing
video poker in 1997 and spent an increasing amount of time
engaged in the activity.
Video poker is a “casino game based on five card draw
poker.” Http://en.wikipedia.org/wiki/Video_poker. Players bet
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