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VALENTI v. COMMISSIONER

Docket No. 12836-92.

68 T.C.M. 838 (1994)

T.C. Memo. 1994-483

Pete C. Valenti and Peggy R. Valenti v. Commissioner.

United States Tax Court.

Filed October 4, 1994.

Attorney(s) appearing for the Case

Paul R. Roper, 595 W. Lambert Rd., Brea, Calif., for the petitioners. Guy H. Glaser, for the respondent.

Memorandum Opinion

RAUM, Judge:

The Commissioner determined income tax deficiencies of $43,175 and $12,404 for petitioners' 1988 and 1989 taxable years. At issue is whether petitioners were entitled to deduct wagering losses in excess of wagering gains for each of those tax years, pursuant to section 1621 or were instead prohibited from deducting such amounts by reason of section 165(d). The facts have been stipulated. All references...

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