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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 such
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