- 2 -
Unless otherwise indicated, all section references are to
the Internal Revenue Code, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
Background
Graciano V. Espinoza (decedent) died on January 12, 2002,
survived by his wife Elvira, decedent’s executrix herein, and
other unnamed relatives.
During 2000 and in prior years, decedent was addicted to
slot machine gambling. Decedent’s gambling activities occurred
at casinos in Reno, Nevada.
During 2000, decedent put a total of approximately $7
million into slot machines at the Nevada casinos via either cash
or casino credit card, and decedent won 526 tax-reportable
jackpots paying decedent total winnings of $2,580,200 with an
average jackpot of approximately $5,000. Also during 2000,
decedent won other nonjackpot or “hand-paid” winnings.
During 2000, decedent purchased an automobile with $10,000
in cash (in 100 $100 bills).
In early 2001, the Nevada casinos at which decedent gambled
mailed to respondent numerous Forms W-2G, Certain Gambling
Winnings, for 2000, the cumulative total of which reflected
decedent’s $2,580,200 in slot machine jackpots.
The above Forms W-2G did not include decedent’s other “non-
jackpot” slot machine winnings and did not reflect decedent’s
gambling losses.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011