CUMMINGS, Chief Judge.
The sole issue presented in this appeal is whether the Tax Court erred in holding that the taxpayer's gambling activities constituted a "trade or business" for purposes of Section 62(1) of the Internal Revenue Code, 26 U.S.C. § 62(1). The Commissioner asserts that the taxpayer's failure to hold himself out to others as offering goods or services precludes characterization of his activities as a trade or business. We disagree and affirm...
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