- 2 - Satrang for lack of prosecution, we must decide whether Leroy Vernon Satrang (petitioner) may deduct his alleged gambling losses. We hold he may not. We also must decide whether petitioner is liable for the accuracy-related penalty determined by respondent. We hold he is. Unless otherwise indicated, section references are to the Internal Revenue Code as applicable to the subject year, Rule references are to the Tax Court Rules of Practice and Procedure, and dollar amounts are rounded to the nearest dollar. Some facts have been stipulated and are so found. The stipulated facts and the exhibits submitted therewith are incorporated herein by this reference. Petitioners are husband and wife, and they resided in Sioux City, Iowa, when their petition was filed. Petitioner, a civil engineer by profession, is a recreational gambler who bets primarily on horse races. During the subject year, he won at least 29 of his gambling bets and received a total of at least $32,050 in gambling winnings. He reported none of those winnings on his 1996 Federal income tax return even though he received Forms W2-G, Gambling Winnings, listing those winnings. He asserts that none of the winnings are taxable to him because his gambling losses during that year totaled more than $70,000. His employer paid $51,600 toPage: Previous 1 2 3 4 5 6 Next
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