- 2 - 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. Background 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.Page: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: November 10, 2007