Ronald J. Lutz, Jr. and Paula M. Lutz - Page 6




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                                             Winnings       Losses                    
               Boomtown Casino               $2,645         $1,690                    
               Jubilation Casino             3,100          1,550                     
               On their 1996 joint Federal income tax return, petitioners             
          reported no income or losses from their gambling activities.                
          They reported $104,000 wage income from Mega.                               
               Respondent commenced an examination of petitioners’ 1996               
          joint Federal income tax return in December 1998.  In the notice            
          of deficiency, issued in March 1999, respondent determined that             
          petitioners had $91,000 unreported gambling income.  Respondent’s           
          determination was based on gambling winnings reported on 18 Forms           
          W-2G–-two from Jubilation Casino (showing $3,100 total gross                
          winnings), eight from the Bay St. Louis Casino Magic (showing               
          $61,000 total gross winnings), seven from the Biloxi Casino Magic           
          (showing $24,900 total gross winnings), and one from Boomtown               
          Casino (showing $2,000 total gross winnings).                               
                                       OPINION                                        
               Petitioners contend that their 1996 gambling losses more               
          than offset their gambling winnings and that respondent’s                   
          determination is therefore in error.  Respondent concedes that              
          petitioners had $43,818.75 of gambling losses in 1996, based                
          largely on the THRs generated by the Casinos Magic with respect             
          to petitioners’ table games play.  Respondent contends, however,            
          that petitioners had at least $144,645 of unreported gambling               
          winnings in 1996, and that the notice of deficiency reflects only           





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