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Park v. Commissioner

United States Court of Appeals for the District of Columbia Circuit
722 F.3d 384 (2013)

Written by Nathan Benedict, JD

Facts

Sang Park (plaintiff), a South Korean citizen, gambled on slot machines in the United States. The Internal Revenue Service (IRS) (defendant) sought to count every winning bet as taxable income. Park argued that his winnings should be calculated on a per-session basis, such that he would owe no tax on sessions in which he recorded an overall loss. The tax court ruled for the IRS, and Park appealed.

Rule of Law

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Issue

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Holding and Reasoning (Kavanaugh, J.)

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A "yes" or "no" answer to the question framed in the issue section;
A summary of the majority or plurality opinion, using the CREAC method; and
The procedural disposition (e.g., reversed and remanded, affirmed, etc.).

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