- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011