Gambling Losses Agi

The TCJA also provides that losses from wagering transactions are limited to the amount of your reported winnings. You can use your losses to offset your gambling income, but you can't use any losses that are left over from your other sources of income.

  1. Can You Claim Gambling Losses Against Wins
  2. Gambling Losses For Or From Agi
Tax Court Memo 2017-118Winnings

Gambling losses are deductible only to the extent of gambling winnings and are reported as itemized deductions on Schedule A that are not subject to the 2%-of-adjusted-gross-income threshold; therefore, deductions for gambling losses are not among the miscellaneous itemized deductions suspended by the Tax Cuts and Jobs Act of 2017 (TCJA). Gambling Losses You may deduct gambling losses only if you itemize your deductions on Schedule A (Form 1040 or 1040-SR) PDF and kept a record of your winnings and losses. The amount of losses you deduct can't be more than the amount of gambling income you reported on your return.

I'm missing something in this TC Memo. (Or I have a gross conceptual error.)
Petitioner had employee wages of $68,879
Petitioner had gambling winnings of $94,000
Petitioner had passive losses from rental real estate of $40,968
Petitioner had gambling losses to offset all gambling winnings
The case pertains to petitioner's claim that she was a real estate professional and she should be able to claim all of her passive losses. She was found not to be a real estate professional.
However, this phrase throws me:
Gambling

Can You Claim Gambling Losses Against Wins

'Respondent [the IRS] also determined that petitioner
actively participated in her rental activities and that she could offset up to $25,000
of the rental activity loss against nonpassive income for 2011.'

Wouldn't the gambling winnings wreck her AGI and put her over the $150K income threshold? Wouldn't

Gambling Losses For Or From Agi

all of her passive losses be suspended? The deficiency determined in the case ($2,475) suggests the IRS determined the $25,000 in passive losses were not suspended. Why would her AGI not be over the threshold to take the losses in 2011?