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Commissioner v. Groetzinger
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Commissioner v. Groetzinger : ウィキペディア英語版
Commissioner v. Groetzinger

''Commissioner v. Groetzinger'', is a decision of the Supreme Court of the United States, which addressed the issue of what qualifies as being either a trade or business under Section 162(a) of the Internal Revenue Code.〔480 U.S. 23 (1987).〕〔26 U.S. Code 162(a).〕 Under the terms of § 162(a), tax deductions should be granted "for all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any ''trade or business'' for tax purposes."〔''Id.''〕 However, the term "trade or Business" is not defined anywhere in the Internal Revenue Code.〔''See'' Donaldson (2007), p. 223.〕 The case of ''Commissioner v. Groetzinger'' examined what is required for an activity to rise to the level of a "trade or business" for tax purposes. The particular question presented in this case was whether a full-time gambler who made wagers for his own account was engaged in a "trade or business."
==Holding==
In the absence of an all-purpose definition by statute or regulation, the Court decided not to create a specific test to determine what qualifies as a trade or business.〔 Instead, the Court found that such a decision requires an examination of the facts in each case.〔 As for gambling in particular, the Court concluded that "if one's gambling activity is pursued full time, in good faith, and with regularity, to the production of income for livelihood, and is not a mere hobby" it is a trade or business within the meaning of §162(a) of the Internal Revenue Code.〔480 U.S. 23, 35〕

抄文引用元・出典: フリー百科事典『 ウィキペディア(Wikipedia)
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