Edward B. Rood - Page 12

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          1985, not during December of that year as petitioner claims.4               
          Because the records show that the casino made no additional                 
          extensions of credit to petitioner subsequent to October 1985,              
          there is no support in those records for petitioner’s contention            
          that his indebtedness to the casino arose as a result of events             
          occurring during early December 1985.  Furthermore, petitioner              
          does not claim that there was any dispute concerning his                    
          liability for or the amount of any of his debts to Caesar's that            
          arose prior to December 1985.                                               
               Moreover, nothing in those records supports petitioner’s               
          contention that he incurred a debt to Caesar’s of $80,000 during            
          the December 1985 tournament due to gambling losses, which losses           
          formed the basis for a portion of the debt that he acknowledged             
          that he owed Caesar’s.  As noted above, Caesar’s records show no            
          new debt arising during December 1985.  In light of petitioner's            
          claims, we are nonplussed by the failure of those records to even           
          indicate that petitioner made a trip to Caesar’s during December            


          4                                                                           
               The entries in the casino’s records for December 1985                  
          increasing the amount of petitioner’s debt reflect the return of            
          checks petitioner had given the casino during October 1985, and             
          not the extension of new credit to petitioner.  Petitioner                  
          maintains that those checks were paid but points to no evidence             
          in the record to support that contention, and we have found none.           
          Indeed, petitioner’s contention that the returned checks were               
          paid is contradicted by the entries in Caesar’s records that show           
          that, after one check for $110,000 was entered on Caesar’s                  
          records as returned, a second check in that amount was sent to              
          Caesar’s, which was also returned.                                          





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