- 4 -
the amounts spent or won playing bingo during 1994. They saved
some admission receipts and cards, but these documents were
discarded prior to the time that they were notified that their
1994 year was under examination.
During a 6- or 7-week period in 1994 Mrs. Smith was
particularly lucky. She enjoyed $12,600 in bingo winnings, which
were reported to her and respondent on Forms W-2G.
Petitioners included $5,950 in bingo winnings in the income
reported on their 1994 Federal income tax return. The manner in
which that amount was calculated was not explained on the return.
They did not include any portion of the disability benefits
received by Mr. Smith in their reported income.
In the notice of deficiency respondent increased
petitioners' income by the excess of the amount of bingo winnings
reported on the Forms W-2G over the amount reported on their
return. Respondent also increased petitioners' income by the
amount of disability benefits received by Mr. Smith. Other
adjustments were made in the notice of deficiency but are not in
dispute in this case.
OPINION
Bingo Winnings and Losses
Although raised in the context of unreported gambling
income, in essence the controversy between the parties focuses
upon the allowance of a gambling loss deduction. In general,
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011