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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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