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Commissioner v. Groetzinger

United States Supreme Court
480 U.S. 23 (1987)


For his livelihood, Robert Groetzinger (plaintiff) depended solely on his income from gambling on dog races, on which he spent between 60 and 80 hours a week. In 1978, Groetzinger suffered a net gambling loss. The commissioner of internal revenue (defendant) determined that, under the alternative-minimum-tax law in effect in 1978, a portion of Groetzinger’s losses was a taxable item of tax preference. Groetzinger sought a redetermination in the United States Tax Court. The tax court ruled in Groetzinger’s favor, finding that the entirety of Groetzinger’s 1978 losses arose from tax-deductible trade or business activity under § 162(a) of the federal tax code. The court of appeals affirmed. The United States Supreme Court granted certiorari.

Rule of Law


Holding and Reasoning (Blackmun, J.)

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