- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011