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tracking system used to arrive at estimated win or loss
information provides estimates only and does not constitute an
accurate accounting record. * * * This information should be used
as a supplement to your own records or information." The
Caesar’s Palace letter we regard as highly suspect. It is
unsigned. By its terms, it is only an estimate and is to be
supplemented by petitioner’s own records. We regard the letter
as unreliable evidence and give it no weight.
Petitioner has presented no documentation of his gambling
costs. Petitioner acknowledges that he maintained no records of
his gambling activities. Petitioner has failed to satisfy his
burden of proof, and, on the evidence before us, we allow
petitioner no gambling costs for 1994.
Under section 151(b), a taxpayer who does not file a joint
return with his or her spouse may not claim an exemption for the
spouse unless the spouse for the year had no gross income and is
a dependent of the taxpayer. See sec. 1.151-1(b), Income Tax
Regs. Petitioner has presented insufficient evidence regarding
his wife to qualify her as a dependent. We disallow petitioner’s
claim of his wife as an exemption.
Section 6651(a) provides for an addition to tax for failure
to file timely Federal income tax returns unless there is
reasonable cause for such failure. Section 6654(a) generally
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