Losses sustained during the taxable year on wagering transactions shall be allowed as a deduction but only to the extent of the gains during the taxable year from such transactions. In the case of a husband and wife making a joint return for the taxable year, the combined losses of the spouses from wagering transactions shall be allowed to the extent of the combined gains of the spouses from...
The J+O-I of Gambling Income
Much confusion exists about gambling income and how it is calculated. For instance, IRC 165(d) does not even use the term “income” – it mentions losses, gains and transactions – but, it never mentions the term “income.” So how is “gambling income” calculated? The mnemonic “J+O-I” is the easiest way to remember the “gambling...
Sorry, No Pictures.
When I was in law school, it was not uncommon for the female undergraduate students to visit the law school library. Naturally, the fraternity boys were not far behind. However, they were not hard to identify and chase out. It was simple. Law school textbooks do not have any pictures. And, if they do, then it probably is a faded picture of judges in their black robes. The purpose of this website...
Geronimo and Gambling Taxes: The Story Behind a Legendary Warrior Can Prepare You For Tax Time (Strictly Slots Magazine)
Geronimo, the famous Chiricahua Apache warrior, was one of the most feared and respected enemy combatants the United States has ever known. So much so, that he remained a prisoner-of-war until his death on February 17, 1909 in Ft. Sill Oklahoma. While reading a biographical account by one of the U.S. Army officers involved in his capture, I came across an interesting passage. He explained how the...
Taxation of Recreational Gamblers: An Overview of How to Report Wagering Gains and Losses (EA Journal)
Gambling is a $140 billion per year industry. Although the consumer electronics industry is larger ($186.4 billion), the gambling industry is larger than the cable TV ($97.6 billion), outdoor equipment ($11 billion), U.S. box office ($10.2 billion), and U.S. music ($7.0 billion) industries combined. As a matter of fact, in the twenty years from 1991 to 2011, consumer spending on commercial casino...
Taxation of the Recreational Gambler (Tulsa Lawyer Magazine)
With the growth of gambling in Oklahoma, many industries have rushed to provide the needed support and expertise. The area of taxation is no different. Many lawyers and accountants have quickly developed the necessary proficiency to help their clients properly record and report their gambling income. I would like to share with you some of the basic issues so that you may help and at the very...
Jones v. Commissioner of Internal Revenue (2011)
WILLIAM JONES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent. United States Tax Court. T.C. Memo. 2011-77, 2011 WL 1235228 (US Tax Court), 101 T.C.M. (CCH) 1351, T.C.M. (RIA) 2011-077, 2011 RIA TC Memo 2011-077 Docket No. 5776-09. April 4, 2011. Donald J. Mock, for petitioner. Angela B. Friedman, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION HAINES, Judge: Respondent...
Pan v. Commissioner of Internal Revenue (2011)
JIN LONG PAN AND BAO QIONG CHEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent. United States Tax Court T.C. Memo. 2011-40, 2011 WL 597992 (US Tax Court), 101 T.C.M. (CCH) 1177, T.C.M. (RIA) 2011-040, 2011 RIA TC Memo 2011-040 (Cite as: T.C. Memo. 2011-40, 2011 WL 597992 (US Tax Court)) No. 23497-07. February 14, 2011. Robert Nizewitz (specially recognized) and Stephen K. Seung, for...
Shollenberger v. Commissioner of Internal Revenue (2009)
GEORGE D. AND LILLIAN M. SHOLLENBERGER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent. United States Tax Court. T.C. Memo. 2009-306, 2009 WL 5103973 (US Tax Court), 98 T.C.M. (CCH) 667, T.C.M. (RIA) 2009-306, 2009 RIA TC Memo 2009-306 (Cite as: T.C. Memo. 2009-306, 2009 WL 5103973 (US Tax Court)) No. 5504-08. December 28, 2009. Background: Taxpayers petitioned for redetermination of...
LaPlante v. Commissioner of Internal Revenue (2009)
ANN M. LAPLANTE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent. United States Tax Court. T.C. Memo. 2009-226, 2009 WL 3152789 (US Tax Court), 98 T.C.M. (CCH) 305, T.C.M. (RIA) 2009-226, 2009 RIA TC Memo 2009-226 (Cite as: T.C. Memo. 2009-226, 2009 WL 3152789 (US Tax Court)) No. 17591-07. October 1, 2009. Joseph Fitzgibbons, for petitioner. Paul Colleran, for respondent. MEMORANDUM...