Case detail

Commissioner v. Groetzinger

480 U.S. 23 (1987)

Court

Supreme Court

Date

1987-01-13

Outcome

for-taxpayer

Holding

A taxpayer who pursued gambling full time, regularly, and for livelihood was engaged in a trade or business.

Facts

The taxpayer spent full working time on parimutuel wagering and relied on it as a source of income.

Reasoning

The Court emphasized continuity, regularity, and profit-oriented livelihood as the practical hallmarks of a trade or business in this context.

Case metadata

Jurisdiction: United States

Topics: trade or business, deductions

Statutes applied: 26 U.S.C. 162

Official opinion

Open official decision

Primary sources

Official opinion PDFVerified 2026-05-01

Important disclaimer

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