T.C. Memo 2010-54: The court decision located at T.C. Memo 2010-54 is that of David J. And Letitia B. Crawford v. Commissioner of Internal Revenue, appearing as the petitioners and respondent respectively. The Court that Heard the Case: The United States Tax Court. This particular court according to Raabe, Whittenburg, Sanders, Sawyers, and Gill (2011) hears and determines Federal tax cases. In the words of the authors, "its jurisdiction is limited to cases concerning the various Internal Revenue Codes and Revenue Acts that were adopted after February 26, 1926" (Raabe et al., 2011, p. 156).

The Judge(s): B.L. Garber

Case Decided on: March 22, 2010

Issues Involved:

The respondent in this case discovered a deficiency of $2, 230 in the Federal income tax of the petitioners for the year 2006 (U.S. Tax Court, 2010). As the court further points out, the deficiency was, essentially, "attributable to the respondent's disallowance of...

Crawford's (Petitioner's) deductions for losses and some expenses from gambling" (U.S. Tax Court, 2010).
The issues presented for the court's consideration were two in number:

a). Whether net losses attributable to the petitioner's (who regarded himself a professional gambler) gambling activities could be deducted against income derived elsewhere,

And,

b). Whether David J. Crawford (the petitioner) had demonstrated "entitlement to a $2, 400 deduction for 'promotional activities'" (U.S. Tax Court, 2010).

The total net loss from Crawford's gambling related activities amounted to $27,952. It is this loss that Crawford sought to apply, in an attempt to minimize their other income. According to the U.S. Tax Court, that particular deduction, alongside several other deductions, would have resulted in zero tax liability.

It is the interplay between two sections that largely informed discussions in this…