Taxation

TO: Dr. Green FROM: DATE: 9/27/09 RE: measure memorandum #1/Gambling Activities Dr. Green, The first issue is what measure is apply to determine whether your gaming activities constitute a append or business for tax purposes. The criteria has been loosely established in ¶1620.02.C. military operation of Trade or Business and the authoritative Court has chiefly defined the term traffic or business to allow any action at law engaged in with continuity and rule with the objective of making a profit(Groetzinger v. Comr., 480 U.S. 23 (1987). Courts also generally consider the following factors in find whether a throw or business exists: the extent and constitution of gross revenue efforts, the number, continuity, and system of sales, the extent to which the taxpayer attempts to increase sales by improving the stead and advertising, the time and effort devoted to sales by the taxpayer (U.S. v. Winthrop, 417 F.2d 905 (5th Cir. 1969). one court described the inquiry as whether the taxpayer has engaged in a sufficient quantum of focused activity to be considered to be engaged in a mete out or business.( suburban Realty Co. v. U.S., 615 F.2d 171 (5th Cir. 1980).

Since you do non conduct your gambling activities in the same manner and with the same intent to distribute this activity as a profitable business as you do your medical practice, nor do you need to rely on your profit to maintain your living expenses. The second issue is whether or not you can deduct the travel and lodging expenses against your gambling winnings. The Supreme Court has ruled that a professional ri sk taker is authorize to deduct gambling lo! sses as a trade of business expense. The fact that the taxpayer did not offer goods or serve to others did not preclude characterization of the activities as a trade or business, rather, the appropriate business test was that the taxpayer essential be involved in the activity with continuity and order and the taxpayers primary purpose for engaging in the activity...If you exigency to depress a full essay, order it on our website: BestEssayCheap.com

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