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Also in 1988, another loan from Bank Leumi was obtained
apparently in the amount of $1.5 million.1 The evidence does not
establish whether Delta Realty or petitioner was the debtor on
this loan. The proceeds from this loan were used to purchase a
Bank Leumi certificate of deposit (Bank Leumi CD).
For 1988 and 1991, petitioner was issued by Bank Leumi
Forms 1099-INT, Interest Income, indicating that petitioner
received interest income due on the Bank Leumi CD. On the
Form 1099-INT for 1991, it was indicated that petitioner received
$22,192 in interest income on the Bank Leumi CD.
Prior to 1991, petitioner won a large cash prize in the
New York State Lottery with respect to which petitioner during
the years in issue received an annual payment of $101,500.
In January of 1994, petitioner traveled to Las Vegas,
Nevada, and played the slot machines at Caesar’s Palace Casino.
In 1994, petitioner was issued Forms 1099 from Caesar’s
Palace indicating that petitioner had winnings in 1994 of
$162,000 from playing the Caesar’s Palace slot machines.
Petitioner did not maintain any financial records relating to his
gambling winnings and costs.
For 1991, 1993, and 1994, petitioner failed to file Federal
income tax returns.
1 Petitioner claims the loan was for $4 million. However, a
letter from the attorneys who represented Delta Realty suggests
that the loan was in the amount of $1.5 million.
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