We hold the amount is $21,194.01, which is the amount the IRS conceded. The issue to be resolved is the amount of Henley's wagering-loss deduction under section 165(a) and (d). Henley, for the 2013 taxable year, determining an income-tax deficiency of $8,751 and an accuracy-related penalty under section 6662(a) of $1,750. The respondent (referred to here as the “IRS”) issued a notice of deficiency to the petitioner, Teresa J.
This Court has jurisdiction pursuant to section 6213(a). 1 Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.
MORRISON, Judge: This case was heard pursuant to section 7463 of the Internal Revenue Code of 1986, as amended, in effect when the petition was filed. COMMISSIONER OF INTERNAL REVENUE, Respondent
