- 8 -
While the undercover investigation was ongoing,
petitioner was permitted to continue his illegal bookmaking
business and to retain the net proceeds from that business.
Petitioner also continued his gambling activities, includ-
ing betting at various racetracks and casinos. During that
time, petitioner received sizeable winnings and incurred
sizeable losses from his gambling activities. Special
Agents of the FBI were aware of petitioner's gambling at
racetracks and casinos.
Petitioner attached to his 1991 Federal income tax
return 10 Statements for Certain Gambling Winnings on Form
W-2G that report the following gross winnings, Federal and
State tax withholding, and net winnings from three race-
tracks:
Gross Fed. Tax St. Tax Net
Date Winnings Wheld. Wheld. Winnings
N.J. State Sports & Exposition Auth. 01/08/91$8,140.00 $1,626 $244 $6,270.00
N.J. State Sports & Exposition Auth. 01/12/915,527.50 1,105 166 4,256.50
N.J. State Sports & Exposition Auth. 03/09/91626.20 -0- -0- 626.20
N.J. State Sports & Exposition Auth. 03/09/91626.20 -0- -0- 626.20
Garden State Race Track, Inc.05/16/91 652.80 -0- -0- 652.80
N.J. State Sports & Exposition Auth. 05/30/91685.00 -0- -0- 685.00
Philadelphia Park - GRI 06/28/91 2,241.50 447 -0- 1,794.50
Philadelphia Park - GRI 07/30/91 1,801.20 359 -0- 1,442.20
N.J. State Sports & Exposition Auth. 08/01/91918.60 -0- -0- 918.60
Philadelphia Park - GRI 11/11/91 812.60 -0- -0- 812.60
22,031.60 3,537 410 18,084.60
Petitioner also attached a handwritten schedule to his 1991
return that lists 9 of the 10 payments reported on the
Forms W-2G. The handwritten schedule does not list the
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