Taxation

TO: Dr. Green
FROM:
DATE: 9/27/09
RE: Tax memorandum #1/Gambling Activities
Dr. Green,
The first issue is what criterion is apply to determine whether your gambling activities constitute a interchange or business for tax purposes. The criteria has been loosely established in ¶1620.02.C. military operation of Trade or Business and the imperative Court has chiefly defined the term traffic or business to allow any activity engaged in with continuity and rule with the objective of making a profit(Groetzinger v. Comr., 480 U.S. 23 (1987). Courts also generally consider the following factors in determining whether a throw or business exists: the extent and nature of sales efforts, the number, continuity, and system of sales, the extent to which the taxpayer attempts to increase sales by improving the stead and advertising, the time and effort devoted to sales by the taxpayer (U.S. v. Winthrop, 417 F.2d 905 (5th Cir. 1969). one court described the inquiry as whether the taxpayer has engaged in a sufficient quantum of focused activity to be considered to be engaged in a trade or business.( suburban Realty Co. v. U.S., 615 F.2d 171 (5th Cir. 1980).



Since you do non conduct your gambling activities in the same manner and with the same intent to treat this activity as a profitable business as you do your medical practice, nor do you need to rely on your profit to maintain your living expenses.
The second issue is whether or not you can deduct the travel and lodging expenses against your gambling winnings. The Supreme Court has ruled that a professional gambler is authorize to deduct gambling losses as a trade of business expense. The fact that the taxpayer did not offer goods or serve to others did not preclude characterization of the activities as a trade or business, rather, the appropriate business test was that the taxpayer must be involved in the activity with continuity and regularity and the taxpayers primary purpose for engaging in the activity...If you want to depress a full essay, order it on our website: Orderessay



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