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). 1 The tax year…
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