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payment from Garden State Race Track, Inc., shown above,
in the amount of $652.80.
On line 22 of his 1991 return, petitioner reported
other income from "Race Track" in the amount of $21,379.
This amount is $652.60 less than the aggregate winnings
reported on the Forms W-2G attached to his return. The
record does not explain why petitioner reported only
$21,379 of the $22,031.60 shown on the Forms W-2G that
are attached to petitioner's return. Petitioner reported
no income from his gambling at casinos or from his other
gambling activities.
For taxable year 1991, petitioner claimed a deduction
for "gambling losses" in the amount of $19,690.
Petitioner's return does not give any details concerning
this deduction, such as the identity of the payees, the
dates, or the amounts paid. This amount is claimed as
miscellaneous itemized deduction. Thus, petitioner's 1991
return does not claim that petitioner is in the trade or
business of gambling. Petitioner also claimed a credit of
$3,537, the aggregate amount of Federal tax withheld from
the winnings reported on the Forms W-2G attached to his
return.
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