Estate of Graciano V. Espinoza, Deceased, Elvira Expinoza, Executrix - Page 3

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               In May of 2001, decedent filed for bankruptcy.  Decedent               
          listed in his bankruptcy filing total assets of $127,600 and                
          debts in excess of $200,000.  Also, in decedent’s bankruptcy                
          filing it is indicated that during 2000 and 2001 decedent                   
          purchased a $15,000 motorcycle, a $26,000 GMC Savana, a $51,000             
          GMC Sierra, and a $55,000 GMC Denali.  Further, in decedent’s               
          bankruptcy filing, it is indicated that as of May of 2001                   
          decedent owed a total of only $70,000 to the Nevada casinos at              
          which he gambled.                                                           
               Six months later, in September or October of 2001,                     
          decedent’s bankruptcy case was closed.  The record does not                 
          reflect the resolution of decedent’s bankruptcy proceeding.                 
               On decedent’s 2000 Federal income tax return that was filed            
          with respondent, decedent’s $2,580,200 in total jackpot winnings            
          was reported as “Other Income”, and an offsetting miscellaneous             
          itemized deduction in the amount of $2,580,200 was claimed on               
          Schedule A, Itemized Deductions, as “gambling losses”.                      
               On decedent’s 2000 Federal income tax return, no gambling              
          winnings were reported other than the above $2,580,200 in jackpot           
          winnings reflected on the Forms W-2G that were mailed to                    
          respondent by the Nevada casinos.                                           
               Also reported as income on decedent’s 2000 Federal income              
          tax return were total wages of $25,300, and interest income of              
          $182.                                                                       






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