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credible corroborating evidence concerning his gambling activ-
ities affords the Court no opportunity to estimate petitioner's
alleged sustained losses under the rule of Cohan v. Commissioner,
supra. Accordingly, we hold that petitioner has failed to carry
his burden of proof with respect to the gambling loss substantia-
tion issue and that his gross gambling winnings are taxable as
determined by the Commissioner for the year in question.
1991 Taxable Year
On his 1991 return, petitioner reported $203,567 in gambling
winnings and $187,000 in losses. Attached to the return were
Forms W-2G reflecting $92,6265 in dog track winnings won by
petitioner and reported to respondent by the tracks. After
audit, respondent determined that petitioner had failed to report
$137,946 in gambling winnings. Respondent also made a correla-
tive adjustment, increasing petitioner's gambling losses by
$104,478. Petitioner challenges the 1991 deficiency on the
grounds that respondent had no basis to suspect that petitioner
earned more income than reported, respondent inappropriately and
incorrectly applied extrapolation, and respondent is unable to
establish, using a net worth method or any other method, that
petitioner made or lost more than he reported on his 1991 Federal
income tax return.
5The parties both stated that petitioner's Forms W-2G
attached to his 1991 Federal income tax return totaled $95,707 in
dog track winnings. However, the Forms W-2G attached to
petitioner's 1991 Federal income tax return received into
evidence totaled $92,625.70.
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