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taxable years 1990 and 1991 under section 6662(a)1. The issues
for decision are:
1. Whether petitioner is entitled to deductions for gambling
losses during the tax year 1990. We hold that he is not.
2. Whether petitioner failed to report gambling winnings for
the tax year 1991. We hold that he did.
3. Whether a penalty should be imposed against petitioner
under section 6662. We hold that it should.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are incorpo-
rated herein by this reference. At the time the petition was
filed, petitioner resided in Broomfield, Colorado.
Petitioner is a professional gambler. In 1972, after
serving three tours of duty in Vietnam, petitioner was stationed
as the Post Adjutant of Rocky Mountain Arsenal in Denver,
Colorado. It was at this time that petitioner's gambling
activity started. By 1977, petitioner had developed a gambling
addiction. Petitioner was discharged from the military in 1978
after being convicted of stealing Government property to support
his gambling addiction.2 Petitioner was incarcerated twice for
1All section references are to the Internal Revenue Code in
effect for the years in issue, unless otherwise indicated.
2Petitioner testified that he declared the money he received
from the sale of the stolen Government property on his 1977
Federal income tax return.
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