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NOTO v. UNITED STATES

Civ. A. 83-3952.

598 F.Supp. 440 (1984)

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

United States District Court, D. New Jersey.

September 21, 1984.

Attorney(s) appearing for the Case

Harvey R. Poe, Livingston, N.J., for plaintiffs.

Stephen T. Lyons, Trial Atty., Tax Div., U.S. Dept. of Justice, Washington, D.C., for defendant.

MEMORANDUM OPINION

LACEY, District Judge.

There is only one issue left to be decided in this action:1 whether the gambling activities of plaintiff Louis Noto2 during 1978 constitute a "trade or business" within the meaning of Sections 62(1) and 162(a) of the Internal Revenue Code (the Code), 26 U.S.C. §§ 62(1) and 162(a).3 Plaintiff says that they do and seeks...

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