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Respondent determined a deficiency of $817 in petitioner's
2000 Federal income tax. This Court must decide whether
petitioner has unreported income for 2000.
Some of the facts in this case have been stipulated and are
so found. Petitioner resided in Henderson, Nevada, at the time
he filed his petition.
During taxable year 2000, petitioner was employed as a
pharmacy technician at Merck-Medco. Petitioner filed a 2000 Form
1040EZ, Income Tax Return for Single and Joint Filers With No
Dependents. Petitioner reported $14,774.75 on line 1 and $546 on
line 3, for an adjusted gross income of $15,320.75. Petitioner
attached to his 2000 tax return a Form W-2, Wage and Tax
Statement, in the amount of $14,774.75, and a Form 1099-G,
Certain Government Benefits, in the amount of $546.
Respondent received three Forms W-2G, Certain Gambling
Winnings, for the year 2000, two from El Dorado Casino (El
Dorado) in the amounts of $2,000, marked “poker”, and $1,466,
marked “slot”, respectively, and one from Sunset Station Hotel &
Casino (Sunset Station) in the amount of $2,000, marked “slots”.
From these Forms W-2G, respondent determined that petitioner had
unreported gambling income of $5,466 for taxable year 2000.
Section 61(a) provides that gross income includes all income
from whatever source derived unless excludable by a specific
provision of the Code. No specific code section excludes
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