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Court acknowledges that petitioner most likely had some gambling
losses during the year, we are unable to determine (either with
specificity or by estimation) the amount of those losses on the
basis of the record at hand. We conclude that petitioner has
failed to satisfy his burden of proof on this issue. See Mayer
v. Commissioner, T.C. Memo. 2000-295, affd. 29 Fed. Appx. 706 (2d
Cir. 2002); see also Zielonka v. Commissioner, T.C. Memo. 1997-
81. Therefore, we are unable to allow any deduction for gambling
losses.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011