Memorandum Findings of Fact and Opinion
PARR, Judge:
Respondent determined deficiencies in petitioner's income tax in the amounts of $1,434.56 and $2,146.00 for the years 1980 and 1981, respectively. The issue for decision is whether respondent was correct in treating the ordinary and necessary expenses relating to petitioner's gambling business as part of his "losses from wagering transactions", for purposes of limiting under section 165(d)
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