Commissioner of Internal Revenue v. Groetzinger (480 U.S. 23)
U.S. Supreme Court · decided February 24, 1987 · Supreme Court Database (Spaeth)
- Citation
- 480 U.S. 23 · 107 S. Ct. 980
- Decided
- February 24, 1987
- Term
- October Term 1986
- Vote
- 6–3
- Majority author
- Justice Blackmun
- Issue area
- Federal Taxation
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Conservative
Opinion excerpt
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 1964, as amended, 26 U. S. C. §§ 162(a) and 62(1) (1976 ed. and Supp. V). The tax year with which we here are concerned is the calendar year 1978; technically, then, we look to the Code as it read at that time. I There is no dispute as to the facts. The critical ones are stipulated. See App. 9. Respondent Robert P. Groet-zinger had worked for 20 years in sales and market research for an Illinois manufacturer when his position was terminated in February 1978. During the remainder of that year, respondent busied himself with parimutuel wagering, primarily on greyhound races. He gambled at tracks in Florida and Colorado. He went to the track 6 days a week for 48 weeks in 1978. He spent a substantial amount of time studying racing forms, programs, and other materials. He devoted from 60 to 80 hours each week to these gambling-related endeavors. He never placed bets on behalf of any other person, or sold tips, or collected commissions for placing bets, or functioned as a bookmaker. He gambled solely for his own account. He had no other profession or type of employment. Respondent kept a detailed accounting of his wagers and…
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