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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.
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Last modified: May 25, 2011