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chooses upon the taxpayer whose inexactitude is of his own
making." Cohan v. Commissioner, 39 F.2d 540, 544 (2d Cir. 1930).
In cases involving gambling loss deductions, this Court has
invoked the rule of Cohan only when satisfied that the taxpayer
incurred some gambling losses, see Drews v. Commissioner, 25 T.C.
1354 (1956); Doffin v. Commissioner, T.C. Memo. 1991-114; Forman
v. Commissioner, T.C. Memo. 1988-64; Kalisch v. Commissioner,
T.C. Memo. 1986-541, affd. without published opinion 838 F.2d 461
(3d Cir. 1987), and there is some basis upon which an estimate of
such losses can be made. Vanicek v. Commissioner, 85 T.C. 731,
743 (1985). However, before we allow a gambling loss deduction
based upon estimates, we must be convinced that the taxpayer's
gambling losses exceeded unreported gains from gambling
transactions. Donovan v. Commissioner, 359 F.2d 64 (1st Cir.
1966), affg. per curiam T.C. Memo. 1965-247; Schooler v.
Commissioner, 68 T.C. 867 (1977); Scoccimarro v. Commissioner,
T.C. Memo. 1979-455.
Obviously, petitioners sustained gambling losses during
1994; equally as obvious, however, is the fact that they enjoyed
unreported bingo winnings. In this case, because petitioners
received unreported bingo winnings, they must establish that
their annual bingo losses exceeded their annual unreported bingo
winnings in order to be entitled to a deduction for bingo losses.
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