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transactions at the casinos, the mere fact of these transactions
does not substantiate actual losses of those funds on gambling.
See Schooler v. Commissioner, 68 T.C. at 870; Klabacka v.
Commissioner, T.C. Memo. 1987-77.
Petitioners presented testimony of casino employees,
indicating that the odds of beating the casinos over the long
haul are not good. We do not doubt it. Such generalizations,
however, do not tend to substantiate petitioners’ actual gambling
losses or provide us any basis for estimating them.
Petitioners rely upon Doffin v. Commissioner, T.C. Memo.
1991-114, to establish that they are entitled to deduct gambling
losses. In Doffin, the taxpayer had $46,240 lottery winnings in
one year and $32,571 in another. The taxpayer kept no records of
gambling losses. The Commissioner allowed the taxpayer a
deduction for gambling losses limited to the costs of the winning
lottery tickets ($494) in one of the years at issue. The
Commissioner allowed the taxpayer no gambling losses for the
other year. The evidence in Doffin showed that the taxpayer, who
lived in a mobile home and had few assets and little income, had
sold assets and borrowed money during the years at issue to
support his gambling habit. The taxpayer’s lifestyle and
financial position indicated no accessions to wealth commensurate
with the amount of net gambling winnings determined by
respondent. Finding it highly improbable that the taxpayer would
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