Ali and Arlene Mohammadpour - Page 3
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other court, and this opinion shall not be treated as precedent
for any other case.
Respondent determined a $1,410 deficiency in petitioners’
2003 Federal income tax. The underlying issue to be resolved is
whether Ali Mohammadpour’s (Mr. Mohammadpour) gambling activity
constituted a trade or business. Resolution of this issue will
affect petitioners’ entitlement to a claimed child tax credit and
the amount of petitioners’ allowable itemized deductions.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits attached thereto are
incorporated herein by this reference.
Mr. Mohammadpour is a certified public accountant. During
2003, he conducted an accounting services business as a sole
proprietorship. Arlene Mohammadpour was employed elsewhere as a
Petitioners timely filed a joint Form 1040, U.S. Individual
Income Tax Return, for 2003 in which they reported adjusted gross
income of $59,917 and claimed a child tax credit of $1,200. In
computing their adjusted gross income, petitioners reported
$41,246 of wage income and, by means of a Schedule C, Profit or
Loss From Business, reported $21,553 of net profit from Mr.
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Last modified: November 10, 2007