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Gloria Tschetschot, pro se.
J. Anthony Hoefer, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
ARMEN, Special Trial Judge: Respondent determined a
deficiency in petitioners’ Federal income tax for the taxable
year 2000 of $10,071, as well as an accuracy-related penalty for
a substantial understatement of income tax of $2,014. The
grounds for the deficiency were the limitations of section 165(d)
as applied to Gloria Tschetschot’s (Mrs. Tschetschot)
professional tournament poker playing and George E. Tschetschot’s
(Mr. Tschetschot) status as a nonprofessional gambler.1 At
trial, petitioners conceded that Mr. Tschetschot was not a
professional gambler but argued that Mrs. Tschetschot’s
professional tournament poker playing is not gambling and thus
not subject to the limitations of section 165(d) on losses from
gambling. Respondent conceded that Mrs. Tschetschot’s business
expenses related to her professional gambling activity were
deductible. Thus, the two issues for decision are: (1) Whether
Mrs. Tschetschot’s tournament poker losses are limited by section
165(d) to the amount of her tournament poker winnings, and (2)
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code of 1986, as amended, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
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