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very many other expenses during those years.
During 1999 and 2000, petitioners made a number of trips to
Atlantic City, New Jersey (Atlantic City), where they, inter
alia, gambled at slot machines at various gambling establish-
ments, including Tropicana, Trump Taj Mahal, Resorts Atlantic
City, and Harrah’s.3 During 1999 and 2000, petitioners did not
maintain the records required by the Code to substantiate any
gambling losses that they incurred during each of those years.
For 1999, Harrah’s issued to Mr. Hartsock at least three
substitute forms in lieu of Forms W-2G, Certain Gambling Winnings
(Harrah’s substitute 1999 Form W-2G),4 with respect to the fol-
lowing respective dates: August 13 and 14 and September 4, 1999.
Harrah’s substitute 1999 Form W-2G issued to Mr. Hartsock
with respect to August 13, 1999, showed, inter alia, the follow-
ing gross winnings of Mr. Hartsock from each of several slot
machines that he played at Harrah’s, the time of such gross
winnings from each such machine, and the minimum amount required
to be wagered in each such machine:
3During 1999, Ms. Hartsock traveled with her parents, and
without Mr. Hartsock, to Atlantic City, where she gambled at at
least one gambling establishment.
4The instructions for Form W-2G, Certain Gambling Winnings,
with respect to 1999 stated in pertinent part: “If the [gam-
bling] winnings (not reduced by the wager) from a * * * slot
machine are $1,200 or more, they are reportable gambling win-
nings.”
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