Revenue – primary goal


§165(d) – deductibility of gambling losses to extent of gains –



Download 106.09 Kb.
Page19/35
Date27.05.2021
Size106.09 Kb.
1   ...   15   16   17   18   19   20   21   22   ...   35

§165(d) – deductibility of gambling losses to extent of gains – during taxable years of such transactions. Gain from discharge of debt came in 1981 but losses in 1980.

  • Purchase price adjustment argument – §108(e)(5) – but chips only bought “opportunity to gamble” not property.

  • WAIT! Third Circuit reverses this opinion – treats as disputed debt and also Zarin did not hold property b/c he was not liable on the debt and therefore cancellation of indebtedness provisions don’t apply and there is no income.

  • Excluding discharge of indebtedness income –
  • 1   ...   15   16   17   18   19   20   21   22   ...   35




    The database is protected by copyright ©essaydocs.org 2020
    send message

        Main page