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Collins v. Commissioner
United States Court of Appeals for the Second Circuit
3 F.3d 625 (1993)
Collins (plaintiff) worked for an off-track horse betting parlor. Collins placed $80,280 worth of bets for himself without paying for them. At the end of the day, Collins had $42,175 in winning tickets. Collins ended up pleading guilty to grand larceny. The Internal Revenue Service (IRS) (defendant) taxed the full amount of Collins’s larceny: $80,280. The tax court affirmed the IRS’s decision. Collins appealed.
Rule of Law
Holding and Reasoning (Cardamone, J.)
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