Edward B. Rood - Page 2

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          income from the cancellation of an allegedly disputed gambling              
          debt written off by a casino.  Unless otherwise indicated, all              
          section references are to the Internal Revenue Code as in effect            
          for the year in issue, and all Rule references are to the Tax               
          Court Rules of Practice and Procedure.                                      
                                  FINDINGS OF FACT                                    
               Some of the facts and the exhibits have been stipulated for            
          trial pursuant to Rule 91.  The parties’ stipulations are                   
          incorporated herein by reference and are found accordingly.                 
               During 1988 and when the petition in the instant case was              
          filed, petitioner resided in Tampa, Florida.                                
               Petitioner is an attorney who was recognized in 1991 for 50            
          years of membership in the Florida Bar.  He is a former president           
          of the Association of Trial Lawyers of America, the Tampa and               
          Hillsborough County Bar Associations, the Florida Academy of                
          Trial Lawyers, and the Junior Bar of the State of Florida.                  
               Prior to 1985, petitioner maintained a line of credit at               
          Caesar’s Palace (Caesar’s or the casino), a casino in Las Vegas,            
          Nevada, where he gambled.                                                   
               To draw on a line of credit, typically, a customer would               
          sign the credit instrument given in exchange for chips (marker),            
          in the gambling pit or at the cashier’s cage in the casino.  A              
          marker could be presented to a customer’s bank by the casino for            
          payment in the same manner as a check.  If a customer wished to             
          allow another to gamble on the customer’s credit, the customer              




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