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  5. 722 F.3d 384 (2013)
 

PARK v. C.I.R.

Nos. 12-1058, 12-1059.

722 F.3d 384 (2013)

Sang J. PARK and Won Kyung O, Appellants v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Appellee.

United States Court of Appeals, District of Columbia Circuit.

Decided July 9, 2013.

Attorney(s) appearing for the Case

Denis M. McDevitt argued the cause for appellants. With him on the briefs was Drew M. Bouchard.

John A. Dudeck Jr. , Attorney, U.S. Department of Justice, argued the cause for appellee. With him on the brief was Richard Farber , Attorney.

Opinion for the Court filed by Circuit Judge KAVANAUGH.

KAVANAUGH, Circuit Judge:

After a night of gambling, it's no fun to walk out of the casino a loser. But it's even worse when the IRS, on your way out, tries to tax you on each individual bet that you happened to win over the course of your losing night. Enter Sang Park, a South Korean businessman who gambled away thousands of dollars at slot machines on casino outings during his trips to the United States — only then to have the IRS seek more in taxes.

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