CTC (Joshua Hamlet - Outline to Testify)

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 an amendment to clarify the statutory treatment and a re-examination of the economic impact certification.