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Respondent determined a deficiency of $998 in petitioner’s
2001 Federal income tax. The issue for decision is whether
petitioner’s gross income includes unreported gambling winnings
and Social Security benefits as determined by respondent.
Background
Some of the facts have been stipulated, and they are so
found. The stipulation of facts and the attached exhibits are
incorporated by this reference. At the time of filing the
petition, petitioner resided in Leesburg, Florida.
In taxable year 2001, petitioner was retired and received
Social Security benefits of $11,088. During the year, petitioner
and a companion traveled throughout the United States to visit
friends and members of petitioner’s family. Petitioner
frequented various casinos to play the slot machines “as a
recreation” during his travels.
Third party information returns (Forms W-2G, Certain
Gambling Winnings) reflect that petitioner received the following
gambling winnings in 2001:
Payor Gambling Winnings
Little River Casino Resort $2,400
Imperial Palace of Mississippi 2,500
Beau Rivage Resorts, Inc. 1,440
Florida Department of the Lottery 1,000
Total 7,340
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