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Trump issued petitioner a 1987, 1988, and 1989 Form
1099-MISC, Miscellaneous Income, reflecting that it paid him the
above-mentioned amounts of comps as "prizes and awards".
Petitioner's 1987 amended return included in his gross income the
amount of comps shown on the 1987 Form 1099-MISC, and it claimed
that petitioner's total deductions from adjusted gross income
equaled the amount of the comps. Attached to petitioner's
amended return were: (1) A copy of the 1987 Form 1099-MISC and
(2) a statement from Trump showing that petitioner's 1987 net
gambling losses at the Casino equaled $4,139,100. The amount of
comps shown on the 1988 and 1989 Forms 1099-MISC were reported on
petitioner's 1988 and 1989 tax returns, respectively, as "Other
income" from "TRUMP PLAZA ASSOC". These returns also claimed a
matching miscellaneous itemized deduction (not subject to the
2-percent floor) for "GAMBLING LOSSES".
Respondent determined that petitioner's gross income for
1987 included the amount shown on the 1987 Form 1099-MISC.7 With
respect to petitioner's 1988 and 1989 taxable years, respondent
determined that petitioner was not entitled to deduct his
gambling losses in the amounts equal to the amounts of the comps.
According to respondent's notice of deficiency, dated
November 12, 1992, "Gambling losses are allowed only to the
extent they offset gains from wagering. Income you received from
7 Respondent's determination did not reflect the fact that
petitioner reported the comps as income on his amended return.
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