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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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Last modified: November 10, 2007