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Because petitioner had $34,805 of adjusted gross income in
2000 (per our redetermination thus far), he was required to
include 85 percent of the Social Security benefits in gross
income. See sec. 86(a)(2), (c)(1) and (2).
The only argument petitioner advances in challenging
respondent's determination is that he attempted to surrender his
Social Security card and instructed the Social Security
Administration to return his contributions. Petitioner conceded,
however, that he cashed all Social Security benefit checks he
received. On this record, we sustain respondent's determination
to include $11,501, 85 percent of the $13,531 of Social Security
benefits received, in petitioner's gross income for 2000.
IV. Deductions
A. Gambling Losses
Section 165(d) provides that losses from wagering
transactions may be deducted to the extent of gains from such
transactions. The burden of substantiating wagering loss
deductions by keeping sufficient records of such deductions is on
the taxpayer. Mayer v. Commissioner, T.C. Memo. 2000-295, affd.
29 Fed. Appx. 706 (2d Cir. 2002); Mack v. Commissioner, T.C.
Memo. 1969-26, affd. 429 F.2d 182 (6th Cir. 1970); sec. 6001;
sec. 1.6001-1(a), Income Tax Regs.
Petitioner produced losing lottery tickets for 2000 totaling
$851, and respondent now concedes that he had wagering losses in
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