- 23 - that Mr. Beck lost $19,600 in 1991 and $15,700 in 1992, and won $3,200 in 1993. Mr. Beck, however, did not have gambling losses during the years at issue. Rather, he had gambling winnings of $1,400 in 1991, $8,300 in 1992, and $12,000 in 1993. Mr. Beck did not report the gambling winnings on his individual returns or the corporation's returns for the years at issue. Because he gambled with the corporation's Canadian currency, Mr. Beck thought that the winnings were taxable to Beck's Liquors. Therefore, in an attempt to "correct" the omission, he reported $20,000 of gambling winnings on the corporation's 1994 return. The winnings, however, are not the income of Beck's Liquors. Even though Mr. Beck used corporate funds for gambling, the winnings are Mr. Beck's income and represent his unreported income in the years at issue. In computing the income of Beck's Liquors, however, we find that the cash expenditures should not include gambling losses. Furthermore, the cash winnings represent a source of cash, and the cash expenditures should be reduced by $1,400 in 1991, $8,300 in 1992, and $12,000 in 1993. c. Insurance Payment The insurance payment was for the vehicle that was destroyed in the accident in which Mrs. Beck was killed. The vehicle was owned by Beck's Liquors. Respondent included insurance proceeds of $6,604 in the gross receipts of Beck's Liquors because, respondent asserts, there was no business use and Mr. Beck cashedPage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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