Your client, Bob Smith, age 70, comes to you for advice regarding whether, for tax purposes, he can be considered to be a professional gambler and, therefore, directly offset his gambling winnings with his gambling losses. Bob follows horse racing very closely. He subscribes to the Daily Race Report, he has read a number of specialized books on developing skills in assessing horses, and makes an annual trip to Louisville to view horse sales and attend the Kentucky Derby. During the past year he went to the races 93 times during which time he won $25,600 and lost $43,000. Bob estimates that he has spent approximately 900 hours during the year in his gambling activities. He estimates he only spent about 800 hours in his "other business," computer consulting. Bob does not have to rely on gambling winnings for his support since, in addition to his consulting income, he receives significant income from Social Security, interest income and a pension