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Petitioner gambled extensively. He played mostly craps, and
he gambled mainly at Trump's casino (the Casino), which was
situated in Atlantic City, New Jersey. In 1987, petitioner spent
84 days at the Casino, gambled on 75 of these days, made an
average bet of $14,964, and had an overall loss of $4,139,100.
In 1988, petitioner spent 179 days at the Casino, gambled on
148 of these days, made an average bet of $11,526, and had an
overall loss of $3,080,050. In 1989, petitioner spent 304 days
at the Casino, gambled on 70 of these days, made an average bet
of $9,226, and had an overall loss of $1,215,900. On many of the
occasions that petitioner played craps at the Casino, his total
bets for one roll of the dice ranged from $50,000 to $100,000.
As a general practice, Trump, in its sole discretion,
voluntarily transferred comps to its patrons to induce them to
patronize the Casino. In some instances, but not in the case of
petitioner, the comps were determined by a formula that allowed
each patron to receive approximately 50 percent of Trump's
anticipated win with respect to him or her.5 The formula took
into account a patron's average bet, the hours that he or she
gambled at the Casino, the estimated number of hands that he or
she played per hour, and a factor set by Trump to reflect the
fact that the odds were in its favor. Trump's senior management
determined the type and amount of petitioner's comps using their
5 With respect to petitioner, Trump’s anticipated win was
$1,531,930 in 1987; $1,861,283 in 1988; and $542,050 in 1989.
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