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Based on the evidence before us, we conclude that the
$22,192 in interest income received on the Bank Leumi CD should
be charged to petitioner. We note particularly petitioner’s
failure to provide any personal bank records that would
substantiate that he did not receive this interest income and
petitioner’s failure to provide any bank records of Delta Realty
that would substantiate petitioner’s claim that Delta Realty
received this interest income.
We are not persuaded that, in spite of the seizure of some
of petitioner’s records, petitioner could not have located and
produced for the Court documentation that would have
substantiated petitioner’s claim that the $22,192 in interest
income was not received by petitioner, if in fact that were true.
Section 165(d) allows a deduction for losses from wagering
transactions to the extent of gains from such transactions. See
sec. 1.165-10, Income Tax Regs. Section 6001 and the
corresponding regulations require taxpayers to keep sufficient
records to substantiate the amount of gross income, deductions,
and credits claimed. See sec. 1.6001-1(a), Income Tax Regs.
Respondent has suggested that taxpayers who gamble regularly
maintain diaries of gambling winnings and costs supplemented by
verifiable documentation to comply with section 6001. See Rev.
Proc. 77-29, 1977-2 C.B. 538. Respondent suggests that the
documentation should contain information regarding the dates and
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