Michael Ferguson - Page 12

                                       - 11 -                                         
                                     Conclusion                                       
              Because petitioner did not have the requisite profit                    
         objective, we decide that petitioner’s gambling activity in 2003             
         was not a trade or business, and consequently, that petitioner               
         was not a professional gambler in the taxable year in issue.                 
              Reviewed and adopted as the report of the Small Tax Case                
         Division.                                                                    
              To reflect our disposition of the disputed issue,                       

                                            Decision will be entered                  
                                       for respondent.                                




























Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  

Last modified: May 25, 2011