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Collins v. Commissioner

United States Tax Court
T.C. Memo 1992-478 (1992)

Written by Kelsey Libby, JD

Facts

Collins (plaintiff) was employed at an off-track horse-betting parlor. In a single day at work, Collins placed multiple bets on his own behalf totaling $80,280 without the funds to pay for them. Collins ended up with $42,175 in winning tickets, resulting in a shortfall of $38,105. Collins was arrested for theft. Collins filed a petition arguing that the $80,280 he placed in bets was not taxable income. The Internal Revenue Service (IRS) (defendant) argued that the full $80,280 was income taxable to Collins.

Rule of Law

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Issue

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Holding and Reasoning (Beghe, J.)

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