- 3 - whether a penalty under section 6662(a) for a substantial understatement of income tax is appropriate. FINDINGS OF FACT At the time the petition was filed, petitioners resided in Cedar Rapids, Iowa. Mrs. Tschetschot is a database project engineer. She was also a professional tournament poker player in 2000.2 Mr. Tschetschot is not a professional gambler but occasionally plays slot machines and blackjack while accompanying his wife on her poker tournament trips. Tournament poker is somewhat different from “live-action” poker. A poker tournament consists of a series of individual events hosted by a casino, and it can last anywhere from several days to 2 weeks. Unlike live-action poker, tournament participants cannot exit the game by cashing out partway through the tournament; tournaments are played until there is one player left with all of the chips. All tournaments have a “buy-in”, or entrance fee, that is paid by the tournament participants to the tournament organizer. A portion of this amount is an administrative fee kept by the casino hosting the event, and the remainder goes directly into the prize fund “pot” that will ultimately be paid out to the 2 Respondent stipulated this fact for purposes of this case only. There are no substantiation issues in this case.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011