Solomon Mayer - Page 7




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            type of specific wagers, the names and addresses of the gambling                           
            establishments, names of witnesses, and the amounts won or lost.                           
            Generally, respondent considers verifiable documentation to                                
            consist of the following:  Forms W-2G (Certain Gambling                                    
            Winnings), actual winnings slips given to taxpayers by casinos,                            
            wagering tickets, credit records, and bank withdrawal forms.                               
                  Where taxpayers fail to satisfy their burden of                                      
            demonstrating the amount of their gambling costs and fail to                               
            provide documentation or other corroborating evidence, we may                              
            disallow claimed gambling costs.  See Zielonka v. Commissioner,                            
            T.C. Memo 1997-81; Klabacka v. Commissioner, T.C. Memo. 1987-77.                           
                  The following schedule reflects petitioner’s and                                     
            respondent’s respective computations of petitioner’s claimed net                           
            gambling winnings for 1994.                                                                

                  Computations of Petitioner’s 1994 Net Gambling Winnings                              
                                                Petitioner              Respondent                     
                  Gross winnings            $837,570            $162,000                               
                  Gambling costs            (898,050)              -0-                                 
                  Lottery winnings              101,500                 101,500                        
            Net winnings           $ 41,020            $263,500                                        

                  At trial, petitioner submitted an unsigned letter from                               
            Caesar’s Palace that indicated that for 1994 petitioner put an                             
            estimated $898,050 into slot machines and had estimated slot                               
            machine winnings of $837,570, for an estimated net gambling loss                           
            (just from slot machines and before taking into account lottery                            
            winnings) of $60,480.  The letter states:  "Please note the                                





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