Comment from Hamlet, Joshua
Joshua HamletOpposeAcademic
Summary: Joshua Hamlet of Clarity Tax Counsel PLLC opposes the proposed regulation because it fails to explicitly address how the 90% wagering loss cap applies to professional gamblers' business expenses under §162. He argues that the regulation's silence creates an interpretive gap that results in "phantom income" for professionals and calls for a re-examination of the "minimal impact" certification.
See attached file(s) - Topic Outline for Testimony on Wagering Losses