The petitioner had no permanent home and lived in casino hotels and gambled at the associated casinos. He lost money gambling and attempted to fully deduct his losses on the basis that he was a professional gambler. The IRS disagreed and the court agreed with the IRS. The court noted that the factors under I.R.C. section 183 are relevant in determining whether the gambling activity is engaged in with the requisite profit intent and that the petitioner could not satisfy the tests. The court noted that the petitioner did not maintain complete and accurate books and records, did not adjust his system of gambling or try to improve "profitability" by changing methods, did not have and did not develop any level of expertise, had no history of success in any business, had substantial income from non-gambling sources which funded his gambling addiction, and enjoyed gambling. As such, the petitioner's gambling losses were deductible only to the extent of his gambling winnings as a miscellaneous itemized deduction. Boneparte v. Comr., T.C. Memo. 2015-128.