Estate of Graciano V. Espinoza, Deceased, Elvira Expinoza, Executrix - Page 5

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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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Last modified: May 25, 2011