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In connection with the Appeals Office consideration of
decedent’s protest, and after some difficulty in scheduling a
meeting with decedent’s accountant, decedent’s accountant met
with and provided to respondent’s Appeals Office a few additional
documents relating to decedent’s gambling winnings and losses.
Decedent’s accountant, however, did not provide to
respondent’s Appeals Office any log or diary of decedent with
regard to decedent’s 2000 gambling activities.
In a March 16, 2004, notice of deficiency mailed by
respondent’s Appeals Office, respondent sustained the adjustment
made by the examining agent to decedent’s claimed gambling losses
(namely, of the total $2,580,200 in gambling losses claimed,
respondent allowed $487,836 and disallowed for lack of
substantiation $2,092,364).
One of the estate’s affidavits indicates that in connection
with the protest and the appeal of respondent’s gambling loss
adjustment, employees in decedent’s accountant’s office spent 9.5
hours contacting employees of the Nevada casinos at which
decedent gambled and gathering documents relating to decedent’s
gambling activities.
On June 21, 2004, Elvira Espinoza, executrix of decedent’s
estate, filed the petition herein.
As part of the pretrial preparation and exchange of
documents, the estate’s counsel provided additional explanation
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