- 4 - gambling winnings reported on the 1989 return represent only winnings for which Forms W-2G were issued. On Schedule A of his 1989 and 1992 returns, petitioner deducted gambling losses in the amount of his reported winnings; i.e., $29,978 and $140,830, respectively. Petitioner filed his income tax returns for 1989 and 1992 in April 1994. 3. The Notice of Deficiency In the notice of deficiency, respondent determined deficiencies in petitioner's Federal income taxes in the amounts of $5,422 and $39,312 for 1989 and 1992, respectively. Specifically, respondent determined that petitioner failed to substantiate his gambling losses. Accordingly, respondent disallowed the gambling loss deductions claimed by petitioner on Schedule A of his 1989 and 1992 returns. In the notice of deficiency, respondent also determined that, for 1989 and 1992, petitioner was liable for (1) additions to tax under section 6651(a)(1) for failure to timely file income tax returns and (2) accuracy-related penalties under section 6662(a) for negligence. OPINION 1. Wagering Losses Section 165(d) provides for a deduction for losses from gambling transactions to the extent of gains from suchPage: Previous 1 2 3 4 5 6 7 8 9 Next
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