- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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