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Cir Vs. Groetzinger

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  • US Supreme Court
  • Jan 01, 1987

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57 entries 4 linked 53 unlinked
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  1. Whipple Vs. Commissioner US Supreme Court · May 13, 1963
  2. United States Vs. Pyne US Supreme Court · Apr 28, 1941
  3. City Bank Farmers Trust Co. Vs. Helvering US Supreme Court · Apr 28, 1941
  4. Charles Ilfeld Co. Vs. Hernandez US Supreme Court · Apr 02, 1934
  5. U.S. 23 (1987) U.S. Supreme Court CIR v. Groetzinger
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  6. U.S. 23 (1987) Commissioner of Internal Revenue v. Groetzinger
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  7. tax for 1978. 82 T.C. 793 (1984). In so ruling, the court adhered to its earlier court-reviewed decision in Ditunno v. Commissioner
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  8. T.C. 362 (1983). The court in Ditunno, id. at 371, had overruled Gentile v. Commissioner
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  9. In one of its early tax cases, Flint v. Stone
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  10. Helvering v. Horst
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  11. With these general comments as significant background, we turn to pertinent cases decided here. Snyder v. Commissioner
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  12. Ibid. Next came Higgins v. Commissioner
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  13. United States v. Gilmore
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  14. or trust in asset conservation and maintenance did not constitute a trade or business. City Bank Farmers Trust Co. v. Helvering
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  15. was made of the Frankfurter concurrence in Du Pont. Yet Justices Reed and Frankfurter were on the Court. Snow v. Commissioner
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  16. Marchetti v. United
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  17. which we doubt, to the Congress, where we feel, at this late date, the ultimate responsibility rests. Cf. Flood v. Kuhn
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  18. Compare Nipper v. Commissioner
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  19. P-H Memo TC (1983), and the Seventh Circuit's decision in the present case, with Gajewski v. Commissioner
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  20. Estate of Cull v. Commissioner
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  21. and Noto v. United
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  22. Tax Court has adhered to its position that a full-time gambler is engaged in a trade or business. See, e.g., Meredith v. Commissioner
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  23. Barrish v. Commissioner
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  24. P-H Memo TC (1984). It has drawn no distinction between the gambler and the active market trader. See also Baxter v. United
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  25. Trent v. Commissioner
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  26. to this Court. See Brief for Petitioner 28, 29, 40, and 61, and Brief for Respondent 17 and 18, in Higgins v. Commissioner
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  27. Levin v. United
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  28. Commissioner v. Nubar
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  29. Fuld v. Commissioner
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  30. F.2d 466, 468-469 (CA2 1943). See also Moller v. United
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  31. Purvis v. Commissioner
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  32. Because the same courts, in cases not involving gamblers, have not referred to the Frankfurter gloss, see Bessenyey v. Commissioner
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  33. Gestrich v. Commissioner
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  34. F.2d 806 (CA3 1982), aff'g, without opinion, 74 T.C. 626 (1980), Main Line Distributors, Inc. v. Commissioner
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  35. when Congress amended the alternative minimum tax provisions in 1982, it implicitly accepted the teaching of Gentile v. Commissioner
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  36. that became apparent when this Court held that a full-time investor is not engaged in a trade or business. See Higgins v. Commissioner
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  37. the practical equivalent of a double deduction,' Charles Ilfeld Co. v. Hernandez
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  38. United States v. Skelly
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  39. U.S. Supreme Court CIR v. Groetzinger
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  40. Commissioner of Internal Revenue v. Groetzinger
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  41. Ditunno v. Commissioner
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  42. Gentile v. Commissioner
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  43. Flint v. Stone
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  44. Helvering v. Horst
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  45. Snyder v. Commissioner
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  46. Higgins v. Commissioner
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  47. the Court. Snow v. Commissioner
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  48. Cf. Flood v. Kuhn
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  49. Gajewski v. Commissioner
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  50. Meredith v. Commissioner
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