Gregory Paul Imberger - Page 4

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          gambling winnings from gross income.  Section 165(d) allows                 
          gambling losses, but only to the extent of gambling winnings.               
          Petitioner did not claim any gambling losses.  No question has              
          been raised in this case with respect to the burden of production           
          under section 6201(d) or the burden of proof under section 7491.            
               Petitioner contends that he did not win the $5,466 reported            
          on the Forms W-2G.  In his petition, petitioner asserts:  “I do             
          not gamble, therefore how could I win this money?”  At trial,               
          petitioner testified:  “I gamble a little bit, like an occasional           
          football game, you know, like the Super Bowl, so I can’t say that           
          I don’t gamble, but not slots.”  Contrary to his testimony,                 
          petitioner opened a customer slot account at Sunset Station in              
          1999.  At trial, petitioner admitted he was a member of the slot            
          club at Sunset Station.                                                     
               The assistant general manager at El Dorado testified that              
          when a player wins $1,200 or more, a “slot floor” employee                  
          (employee) verifies the identity of the winner by obtaining a               
          driver’s license, State-issued identification, military                     
          identification, or passport.  The employee visually verifies that           
          the picture is that of the person before him.  The employee fills           
          out a Form W-2G.  The casino shift manager reviews the                      
          information and approves the jackpot ticket for payment.  El                
          Dorado accepts a verbal Social Security number from a winner who            
          presents other identification.  El Dorado requires winners to               






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Last modified: May 25, 2011