JAMES CASTAGNETTA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent United States Tax Court. T.C. Summ.Op. 2006-24, 2006 WL 325833 (U.S.Tax Ct.) (Cite as: T.C. Summ. Op. 2006-24, 2006 WL 325833 (U.S.Tax Ct.)) No. 22132-03S. February 13, 2006. James Castagnetta, pro se. Frank J. Jackson, for respondent. PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b), THIS OPINION MAY NOT BE TREATED AS...
Hochman v. Commissioner of Internal Revenue (1986)
DAVID HOCHMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent United States Tax Court T.C. Memo. 1986-24, 1986 WL 21421 (U.S.Tax Ct.), 51 T.C.M. (CCH) 311, T.C.M. (P-H) ¶ 86,024, 1986 PH TC Memo 86,024 (Cite as: T.C. Memo. 1986-24) Docket No. 25862-83. Filed January 22, 1986. P was a casual, i.e., nonprofessional gambler, whose gambling losses exceeded his winnings in 1980. He was...
Schooler v. Commissioner of Internal Revenue (1977)
FRED SCHOOLER AND CAROLYN J. SCHOOLER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent</43> United States Tax Court 68 T.C. 867 Docket No. 520-76. Filed September 7, 1977. Held, P, who kept no record of either winnings or losses from racetrack betting, failed to establish that his losses exceeded his unreported income from wagering, and therefore, he was not entitled to a...
Donovan v. Commissioner of Internal Revenue (1965)
DANIEL F. DONOVAN, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Tax Court of the United States. T.C. Memo. 1965-247, 1965 WL 1022 (Tax Ct.), 24 T.C.M. (CCH) 1325, T.C.M. (P-H) P 65,247, 1965 PH TC Memo 65,247 (Cite as: T.C. Memo. 1965-247) Docket No. 5438-63. Filed September 15, 1965. Held: Petitioner failed to establish by competent evidence that his losses from wagering...
Offutt v. Commissioner of Internal Revenue (1951)
ROY T. OFFUTT, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Tax Court of the United States. 16 T.C. 1214 (Cite as: 16 T.C. 1214) Docket No. 21436. Promulgated May 31, 1951. George Bouchard, Esquire, for the petitioner. A. J. Hurley, Esquire, for the respondent. Wagering losses in excess of wagering gains held not available to offset other income nor to create net operating loss...
Silver v. Commissioiner (1940)
MAX SILVER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Board of Tax Appeals. 42 B.T.A. 461 (1940) Docket No. 100186. Promulgated August 6, 1940. Harry Friedman, Esquire, and Joseph A. Bonchi, Esquire, for the petitioner. Charles P. Reilly, Esquire, and John M. Kennedy, Esquire, for the respondent. This is a proceeding to redetermine a deficiency in income tax of $14,737.16 for...
Huntington v. Commissioner of Internal Revenue (1937)
SAMUEL L. HUNTINGTON, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Board of Tax Appeals. 35 B.T.A. 835 (1937) Docket No. 78916. Promulgated April 2, 1937. J. W. Davern, Esquire, for the petitioner. I. Graff, Esquire, for the respondent. The respondent determined a deficiency in petitioner’s income tax for the year 1932 in the amount of $6,965.55. He also added a fraud...
Appeal of Frey (1925)
Appeal of MITCHELL M. FREY, Jr., ET AL., Executors William B. Scaife Estate. Board of Tax Appeals. 1 B.T.A. 338 (1925) Docket No. 391. Submitted December 9, 1924. Decided January 16, 1925. C. Hale Sipe, Esquire, for the taxpayer. Willis D. Nance, Esquire (Nelson T. Hartson, Solicitor of Internal Revenue) for the Commissioner. Before GRAUPNER, LANSDON, LITTLETON, and SMITH. This appeal involves a...