NOTO v. UNITED STATES

Civ. A. No. 83-3952.

598 F.Supp. 436 (1984)

Louis NOTO and Ann Noto, Plaintiffs, v. UNITED STATES, Defendant.

United States District Court, D. New Jersey.

June 6, 1984.


Attorney(s) appearing for the Case

Harvey R. Poe by Gerald Rotunda, Livingston, N.J., for plaintiffs.

Stephen Lyons, Dept. of Justice, Washington, D.C., for defendant.


MEMORANDUM OPINION

LACEY, District Judge.

Before this court is the motion of the Government for summary judgment. The determination of whether a genuine fact issue exists hinges upon the legal question of what legal standard is to be employed by this court to determine whether the gambling activities of plaintiff Louis Noto1 constitute a "trade or business" within the meaning of Sections 62(1) and 162(a) of the Internal Revenue...

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