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gross income under section 61 and adjusted gross income under
section 62. See Hochman v. Commissioner, T.C. Memo. 1986-24.
Similarly, the $39,400 gambling winnings from the Biloxi
Casino Magic is the amount reported as gambling winnings on Forms
W-2G. The record does not expressly indicate whether these gross
winnings are from slot machine or table games play. On the basis
of all the evidence in the record, however, we infer that the
$39,400 winnings are all from petitioners’ slot machine play at
the Biloxi Casino Magic.9 Although the evidence does not
expressly indicate the amounts of bets that petitioners placed to
win these jackpots, we believe that it is a fair inference that
the slot machine payoffs for the Bay St. Louis Casino Magic and
the Biloxi Casino Magic were the same; i.e., 20 to 1.
Accordingly, we infer that petitioners placed aggregate bets of
$1,970 to win the $39,400 at the Biloxi Casino Magic.10
9 This inference is based on several considerations:
According to the Biloxi Casino Magic Trip History Reports (THRs)
that are in evidence, petitioners had only $1,250 table games
winnings at the Biloxi Casino Magic. The smallest amount of
winnings shown on the Biloxi Casino Magic Forms W-2G, however, is
$1,600. All of petitioners’ winnings as reported on the Forms W-
2G from the Biloxi Casino Magic are in amounts greater than
$1,200–-the slot machine threshold amount–-and are in round
numbers, in amounts similar to those reflected on the Bay
St. Louis Casino Magic Forms W-2G. Since the latter Forms W-2G
clearly relate solely to slot machine play, we infer that the
Biloxi Casino Magic Forms W-2G also relate solely to slot machine
play.
10 By contrast, with respect to petitioners’ winnings of
$2,645 and $3,100 from Boomtown Casino in Harvey, La., and
(continued...)
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