T.C. Memo. 2007-38 UNITED STATES TAX COURT GEORGE E. AND GLORIA TSCHETSCHOT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9498-03. Filed February 20, 2007. R disallowed losses in excess of Ps’ winnings from gambling and determined both a deficiency and a penalty for substantial understatement for 2000. After conceding that H’s net gambling losses were not properly deductible, Ps argued that, as a professional tournament poker player, W’s net losses should be treated the same as those of any other professional sport participants. Held: W’s net gambling losses are not exempt from the limitations of sec. 165(d), I.R.C. Held, further: We leave for the parties to determine as part of their computations under Rule 155, Tax Court Rules of Practice and Procedure, whether there was a substantial understatement for the taxable year in issue; if so, Ps are liable for the accuracy- related penalty.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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