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December 1994. The benefits took the form of monthly payments,
the amounts of which took into account his wages at the time of
the accident, worker's compensation payments and other disability
benefits received. During 1994 he received monthly payments
(long-term disability benefits) from Hartford totaling $3,637.
The monthly payments were made by check; the check stubs indicate
that the "taxable pct" of each payment is "100". The payments
were reported as wages on a Form W-2 issued to him by
Consolidated for the year 1994.
Neither petitioner was employed during 1994. Because they
had so much free time and their activities were somewhat limited
by their respective disabilities, they developed an interest in
playing bingo. Many of their friends also played bingo and
petitioners viewed the experience as a social activity as much as
a gambling activity.
During 1994 petitioners attended numerous bingo sessions
conducted at two Indian reservations located within 20 miles of
their residence. Typically, they would attend one or two bingo
sessions per day, 4 to 5 days per week. Mrs. Smith spent between
$27 and $32 per session on various types of games that were
played during the bingo sessions. Mr. Smith spent somewhat less.
Sometimes they won, sometimes they lost, and sometimes they broke
even. Petitioners did not consider breaking even to equate to
winning. Petitioners did not maintain any records that reflect
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