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Prior to 2001, petitioner maintained handwritten tables for
the “speed figures” he prepared. During 2001, petitioner began
using a commercially available computer spreadsheet program to
maintain and prepare the tables for his “speed figures”.
Generally, petitioner makes hand-recorded notes during the race
and then later enters the information into the spreadsheet
program. In addition to maintaining detailed “speed figures”,
petitioner keeps copies of racing forms, racing programs, and
betting tickets as part of his record keeping. He does not
maintain a separate checking account with respect to his gambling
activity.
Petitioner does not advertise that he handicaps horseraces,
nor does he sell the “speed figures” he prepares. He does,
however, offer advice to, and solicit advice from, other regular
gamblers. Petitioner also watches videotapes of the races so he
can “closely” review each race.
Petitioner does not use any wages from his job as a truck
driver to finance his gambling activity. Instead, his wagers are
a fixed percentage of his “bankroll”. Petitioner’s “bankroll”
consists solely of his cumulative winnings at the race track.
Generally, petitioner bets 2.5 percent of his “bankroll” on each
race. During 2001, petitioner earned a 4-percent return on each
dollar bet he placed; i.e., petitioner won on average of $1.04
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Last modified: May 25, 2011