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an estimate.” Although Ms. Frederiksen (using her married name
of Cantrell) testified at trial, she offered no testimony
regarding the source or nature of the information contained in
the two letters.
From the face of the letters, we infer that estimates
therein of petitioners’ net winnings and losses are based on the
casinos’ tracking system. The evidence shows that the casinos
generally did not track slot machine wins and losses unless the
patron used a Players’ Club card. Paula testified that she did
not use her Players’ Club cards when she played slot machines
because she thought they were a “jinx.” Similarly, there is no
evidence that Ronald ever used a Players’ Club Card when he
played slot machines. Accordingly, we conclude that the letters
are unreliable indicators of petitioners’ gambling winnings and
losses, failing in particular to reflect either slot machine
winnings or losses. Cf. Mayer v. Commissioner, T.C. Memo. 2000-
295 (similar unsigned letter from Caesar’s Palace, purporting to
estimate the taxpayer’s gambling winnings and losses, was deemed
to be unreliable evidence and given no weight), affd. 2002 U.S.
App. LEXIS 2838 (2d Cir. 2002).
Petitioners contend that their bank statements and other
documentary evidence show that during 1996 they made cash
withdrawals or debit or credit card charges at the casinos
totaling some $39,329. Assuming that petitioners made such
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