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GENTILE v. COMMISSIONER

Docket No. 509-74.

65 T.C. 1 (1975)

ALFRED A. GENTILE AND CAROLE J. GENTILE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 1, 1975.

Attorney(s) appearing for the Case

Victor Chini, for the petitioners.

David R. Smith, for the respondent.

TANNENWALD, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1971 in the amount of $584.17. The sole issue for determination is whether the gambling activities of petitioner Alfred A. Gentile during the taxable year 1971 constituted the carrying on of a trade or business within the meaning of section 14021 so as to subject the income derived therefrom to inclusion as net earnings...

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