ssue: Are complimentary items $($cash$,$ property$)($comps$),$ which are received by

taxpayer client Compulsive Gambler from Silver Casino, gambling income and may

they be offset by gambling losses under I.R$.$C$.$ section $165($d$)?$

$($A Tax Court memorandum case is likely the authority needed. Of course, a court case

may be the most appropriate authority when it interprets, for example, an I.R$.$C$.$

section and has similar facts to the facts of the taxpayer in this Tax Research Problem.

Possibly other cases, referred to by the most appropriate authority or not, may be

helpful to include in the memorandum.$)$

Facts: Taxpayer Compulsive Gambler has a prior year$$s tax return under examination

by the Internal Revenue Service. At issue, is whether or not complimentary items

$($comps$)$ from Silver Casino are gambling gains under I.R$.$C$.$ section $165($d$)$ and,

thus, can be offset against gambling losses. In the year at issue, Silver Casino

transferred $$400,000($fair market value$)$ of $$comps$$ to Compulsive Gambler.