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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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