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1. General Background
Petitioner began gambling in 1974. Sometime thereafter,
petitioner developed into a compulsive gambler.
During 1989 and 1992, the taxable years in issue, petitioner
attended the dog and horse racing tracks on a regular and
frequent basis. During those years, petitioner gambled on a
full-time basis and was not otherwise gainfully employed.
At trial, petitioner did not introduce any books or records
reflecting his gambling winnings and losses. Petitioner does not
remember whether he maintained books or records reflecting his
gambling winnings and losses for 1989. Petitioner maintained a
gambling log for 1992; however, such log was not accurate
because, in petitioner's opinion, it was "time-consuming to * * *
make it precise".
2. The Income Tax Returns
On his 1989 and 1992 Federal income returns, petitioner
identified his occupation as a "professional gambler" and
reported gambling winnings in the amounts of $29,978 and
$140,830, respectively. Of the $140,830 reported as gambling
winnings on the 1992 return, $90,830 represent winnings for which
Forms W-2G were issued. The remaining $50,000 represent
petitioner's estimate of his winnings for that year. Although
the record is not perfectly clear, it would appear that the
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