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COMMISSIONER v. GROETZINGER

No. 85-1226.

480 U.S. 23 (1987)

107 S.Ct. 980

94 L.Ed.2d 25

COMMISSIONER OF INTERNAL REVENUE v. GROETZINGER

Supreme Court of United States.

Decided February 24, 1987

Attorney(s) appearing for the Case

Albert G. Lauber, Jr., argued the cause for petitioner. With him on the briefs were Solicitor General Fried, Assistant Attorney General Olsen, Alan I. Horowitz, Jonathan S. Cohen, and Bruce R. Ellisen.

Carroll Baymiller argued the cause and filed a brief for respondent.*

JUSTICE BLACKMUN delivered the opinion of the Court.

The issue in this case is whether a full-time gambler who makes wagers solely for his own account is engaged in a "trade or business," within the meaning of § 162(a) and 62(1) of the Internal Revenue Code of 1954, as amended, 26 U. S. C. § 162(a) and 62(1) (1976 ed. and Supp. V).1 The tax year with which we here are concerned is the calendar year 1978; technically, then, we...

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