- 12 - If decedent was not worth much, what was decedent’s source for the $7 million used in 2000 for his gambling activities? As noted, decedent apparently owed the Nevada casinos only $70,000, suggesting that decedent had access to millions of dollars to either play the slot machines with cash or to pay off the casinos to the extent the casinos allowed decedent to play the slot machines on credit (over the $70,000 decedent owed the casinos). In our opinion, neither the fact that decedent incurred large gambling losses nor the fact that decedent filed for bankruptcy establishes for decedent’s estate a negative net worth on the date of death. In 2000, decedent realized large gambling winnings and large gambling losses, but he reported nominal wage income and had significant cash on hand to use for the purchase of an automobile. These facts suggest to us substantial assets, and we believe respondent to have been reasonable in the request for more specific information about decedent’s net worth, which information has not been provided. We commend trial counsel for negotiating a favorable settlement with regard to decedent’s claimed gambling losses. That favorable settlement or concession by respondent, however, does not necessarily translate into an award of administrative costs against respondent, even the relatively modest amount sought herein. See Sokol v. Commissioner, 92 T.C. 760, 767 (1989).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011