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            
          payroll clerk.                                                              
          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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