Facilitating Useful Loss Limitations to Help Our Unique Service Economy (FULL HOUSE) Act
- Sponsor
- Rep. Miller, Max L. [R-OH-7]
- Committees
- Ways and Means Committee (primary)
- Last action
- Jan 8, 2026
Bottom line
The bill restores the previous tax treatment of wagering losses, ensuring that all expenses related to gambling can only be deducted up to the amount of gambling winnings.
What it actually does
This bill amends Section 165(d) of the Internal Revenue Code of 1986 to reinstate the pre-2018 rules for wagering losses. It clarifies that losses from wagering transactions, including any deductions otherwise allowable under the chapter incurred in carrying on any wagering transaction, shall only be allowed to the extent of gains from such transactions. This effectively reverses a change made by the Tax Cuts and Jobs Act of 2017.
Proponents argue
Proponents argue that this bill restores fairness and consistency to the tax code by preventing professional gamblers from deducting business expenses beyond their winnings, aligning with the original intent of the law. They contend it closes a loophole that allowed some to reduce their overall tax liability through gambling-related business expenses, promoting a more equitable tax system.
Opponents contend
Opponents, particularly professional gamblers and industry advocates, might argue that this bill unfairly targets a specific profession by disallowing legitimate business expenses that are deductible in other industries. They contend that if gambling is recognized as a profession, its associated costs should be treated like any other business expense, potentially hindering economic activity in the sector and complicating tax compliance for those who treat gambling as a full-time occupation.
The bill is exceptionally short and clear, making it very accessible for any reader to understand its direct impact with minimal time investment.
Section 2(a), amending Section 165(d) of the Internal Revenue Code of 1986
Reinstatement of Rules for Wagering Losses
This provision amends the Internal Revenue Code to revert the rules for deducting gambling losses to their pre-2018 state. Previously, the Tax Cuts and Jobs Act of 2017 expanded the definition of "losses from wagering transactions" to include all deductions incurred in carrying on any wagering transaction, even if they exceeded gains. This bill reverses that change, meaning that all expenses related to gambling, including travel, lodging, and other business costs for professional gamblers, can only be deducted up to the total amount of gambling winnings.
Supporters argue
Supporters argue this restores the original intent of the law, ensuring that gambling is not treated as a typical business where losses can offset other income indefinitely. It prevents professional gamblers from using business expenses to reduce their overall tax liability beyond their actual gambling gains, promoting fairness in the tax system.
Critics contend
Opponents contend that this provision unfairly singles out professional gamblers, treating their legitimate business expenses differently from those of other professions. They argue that if gambling is recognized as a profession, its associated business costs should be fully deductible, similar to any other business, to accurately reflect net income.
Tradeoffs
The bill balances the principle of treating gambling as a unique activity with specific loss limitations against the principle of allowing legitimate business expenses for professional activities. It creates tension between ensuring tax fairness across different income sources and potentially disadvantaging a specific professional group.