- 6 - handling his case. Petitioner did not ask for nor receive a receipt for these documents. Several weeks later, petitioner received a phone call from his accountant informing him that Mr. Ellison could not locate the programs that petitioner claims to have delivered to the Internal Revenue Service. Petitioner contends that the Internal Revenue Service lost his records when they remodeled and moved the tax auditor's office to a different part of the IRS building. Neither party introduced evidence that petitioner's programs were ever found. While petitioner claims that he and an adult daughter gave a complete set of records to respondent, nothing in the record corroborates it. Additionally, petitioner's daughter never testified, nor did the gentleman handing out the tax forms in the lobby of the Internal Revenue Service office building. Based on the programs for January to June of 1991 that respondent had received, respondent extrapolated the amount of payouts of less than $1,000 ("small" winnings) for the period without programs (July to December 1991) by applying the ratio of "small" winnings to Form W-2G winnings from the period with pro- grams, to the Form W-2G winnings. Respondent then added this amount, plus the winnings reported on the Form W-2G, the "small" winnings reported in petitioner's programs, and petitioner's slot machine winnings to determine petitioner's total gambling winnings.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011