Commissioner v. Groetzinger

Case Date: 05/06/1987

Commissioner v. Groetzinger, 480 U.S. 23 (1987) is a decision of the Supreme Court of the United States, which addressed the issue of what qualifies as being either a trade or business under Section 162(a) of the Internal Revenue Code.[1][2] Under the terms of § 162(a), tax deductions should be granted "for all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business for tax purposes."[3] However, the term "trade or Business" is not defined anywhere in the Internal Revenue Code.[4] The case of Commissioner v. Groetzinger examined what is required for an activity to rise to the level of a "trade or business" for tax purposes. The particular question presented in this case was whether a full-time gambler who made wages for his own account was engaged in a "trade or business."