Ali and Arlene Mohammadpour - Page 9

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          as a second trade or business to that of Mr. Mohammadpour’s                 
          accounting services business, we do not detect the level of                 
          continuity or regularity of gambling activity that is required by           
          Commissioner v. Groetzinger, supra.  Furthermore, we cannot say             
          that the primary purpose of Mr. Mohammadpour’s gambling activity            
          was to make a profit.                                                       
               Concluding, we hold that respondent properly disallowed                
          petitioners’ claimed gambling loss other than as an itemized                
          deduction.  Consequently, petitioners are not entitled to the               
          child tax credit, and their itemized deductions are as determined           
          by respondent.                                                              
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          

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