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contestant on the show in Los Angeles.2 Petitioners' reporting
position is premised on the theory that the foregoing expenses
represent "gambling losses" that may be offset directly against
petitioner's "gambling winnings" from the program.
Respondent determined a deficiency in the amount of $582 in
petitioners' Federal income tax for 1991. Specifically,
respondent determined that petitioners failed to report $1,820 in
income from petitioner's winnings on the "Wheel of Fortune" game
show.3 In respondent's view, the $1,820 in expenses that
petitioner purportedly incurred in attending and participating in
the game show are properly characterized either as nondeductible
personal expenses under section 262 or as miscellaneous itemized
deductions that may only be deducted subject to the 2-percent
floor prescribed by section 67(b).4
2 It would appear that the expenses in issue include a
charge of $58.71 for the cost of printing 200 postcards depicting
petitioner standing on the set of "Wheel of Fortune" with Vanna
White, the program's hostess. Petitioner apparently distributed
the postcards to family and friends.
3 In turn, the resulting increase in petitioners' adjusted
gross income generated a small decrease in petitioners' itemized
deductions pursuant to the limitation set forth in sec. 68.
4 The notice of deficiency states in part: "The expenses
attributable to the taxable [gambling] winnings are reportable on
Schedule A, lines 20 and 24." Petitioners construe this language
to mean that respondent concedes the deductibility of the
expenses in issue. Respondent denies that this language reflects
any concession.
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