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ESTATE OF CULL v. COMMISSIONER

Docket No. 7608-80.

45 T.C.M. 691 (1983)

T.C. Memo. 1983-80

Estate of Dan B. Cull, Deceased, William J. Cull, Administrator, and Connie E. Cull, Surviving Spouse v. Commissioner.

United States Tax Court.

Filed February 8, 1983.

Attorney(s) appearing for the Case

Gerald A. Berk, 55 Public Square, Cleveland, Ohio, Thomas J. Escovar and Benjamin F. Farah, for the petitioners. Kristine A. Roth, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Judge:

By notice of deficiency dated March 6, 1980 respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1977 in the amount of $6,286.81. After concessions, the issues for decision are (1) whether Dan B. Cull was in the trade or business of professional gambling; and, if not, (2) whether respondent correctly determined the amount of minimum tax attributable to the excess...

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