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attributable to gambling transactions are limited by the gains
from such transactions.
Background
This case was submitted fully stipulated, and the stipulated
facts are so found. Petitioners are husband and wife. Their
joint Federal income tax return for each year in issue was timely
filed. At the time that the petition was filed, petitioners
resided in Fairhope, Alabama. References to petitioner are to
William T. Praytor.
As evidenced by numerous Forms W-2G, Certain Gambling
Winnings, issued to petitioner by various casinos, petitioner won
the following amounts from slot machine play (the Form W-2G
winnings):
Year Amount
1994 $49,800
1995 24,950
1996 244,000
The Form W-2G winnings are the exclusive source of gross
income reported on a Schedule C, Profit or Loss From Business,
included with petitioners’ Federal income tax return for each
year. Other items reported on the Schedules C are listed below
(amounts rounded):
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