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respondent under section 7491(a) with respect to the claimed
gambling loss deductions at issue.
We turn now to whether petitioners are entitled for each of
the years at issue to a gambling loss deduction in excess of the
deduction allowed by respondent for each such year.6 To support
their position that they are entitled to such a greater deduction
for each year at issue, petitioners rely on: The testimony of
Mr. Hartsock; the respective Harrah’s substitute 1999 Forms W-2G
with respect to August 13 and 14 and September 4, 1999; Mr.
Hartsock’s checks dated August 13, 1999, totaling $13,000 payable
to Marina Associates; Mr. Hartsock’s checks dated August 14,
1999, totaling $12,000 payable to Marina Associates; Mr.
Hartsock’s $5,100 check dated August 14, 1999, payable to
T.T.M.A., and certain documents (workpapers) that petitioners
prepared and that purport to show how petitioners estimated the
respective amounts of money that they gambled and lost in slot
machines at Harrah’s on each of those dates.
Respondent counters that petitioners have failed to carry
their burden of showing that they are entitled for each of the
years at issue to a gambling loss deduction in excess of the
deduction allowed by respondent for each such year. On the
6Petitioners acknowledge, as they must, that they are enti-
tled for each of the years at issue to deduct gambling losses
only to the extent of their gambling winnings for each such year.
See sec. 165(d).
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