- 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 to
Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011