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T.C. 538, 545 (1976). The burden lies with petitioner to prove
with competent evidence the fact and amount of gambling losses,
if any. See Rule 142(a).
Parimutuel tickets carry little, if any, evidentiary weight
where no corroboration is offered to show that each and every
ticket was a losing ticket purchased by petitioner. See Woosley
v. Commissioner, T.C. Memo. 1982-316; Scoccimarro v.
Commissioner, T.C. Memo. 1979-455. In Scoccimarro v.
Commissioner, supra, we held that parimutuel tickets by
themselves were insufficient to prove that the taxpayer had
sustained gambling losses. We stated that we had
no way of knowing whether petitioner purchased these tickets
or received them from acquaintances and friends at the track
or acquired them by resorting to the time-honored technique
of 'stooping'; i.e., stooping down and picking up the
discarded stubs of disheartened bettors. [Id.]
Similarly, we have no way of determining in this case
whether petitioner had in fact sustained losses at the Yonkers
Raceway. Petitioner has failed to keep adequate records of his
winnings and losses and has not produced any evidence to
corroborate his assertion that all the Race Tickets represent
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