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losses sustained by him. Like the taxpayer in Scoccimarro v.
Commissioner, supra, petitioner could have received the Race
Tickets from friends or acquired them by stooping.
Furthermore, the TPA Complaint does not establish Casino
gambling losses in the amount of at least $50,000. A copy of
petitioner's credit record, attached to the TPA Complaint, shows
that at 8:50 P.M., on July 26, 1994, Trump Plaza Associates
advanced $50,000 to petitioner on his line of credit. On that
same night at approximately 10:00 P.M., Trump Plaza Associates
advanced an additional $100,000 to petitioner. Petitioner
asserts that his credit record proves that he suffered Casino
gambling losses in the amount of $50,000 within 70 minutes.
We disagree. The credit record, without further
explanation, merely indicates that Trump Plaza Associates
extended credit to petitioner totaling $150,000 on July 26, 1994.
Petitioner has offered nothing to support the assertion that the
use of the proceeds resulted ultimately in losses. It is
perfectly possible that the use of the credit line resulted in
net winnings, or in net losses in an amount less than, but not
all of, the entire line of credit, but the 3 items on the 1995
statement of account indicate to us that petitioner's 1994
$150,000 line of credit had been satisfied by some means by the
time the 3 additional extensions of credit were made by Trump
Plaza Associates in 1995. It is therefore not possible to
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