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