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record before us, we agree with respondent.
Petitioners’ focus at trial and on brief is on the gambling
losses that they contend they incurred during the years at issue
at Harrah’s.7 Mr. Hartsock testified that petitioners calculated
their claimed gambling losses at Harrah’s by using the minimum
amount required to be wagered in each slot machine that they
played at Harrah’s as shown on the respective Harrah’s substitute
Forms W-2G with respect to August 13 and 14 and September 4,
1999, the respective times of gambling winnings as shown on such
respective forms, and the respective amounts that they estimated
they would have been able to wager within a minute in each such
slot machine that they played at Harrah’s if they had played two
coins at one time.8 In support of Mr. Hartsock’s testimony,
7According to petitioners, “The gambling losses allowed by
the Respondent for both years in question were those incurred at
all of the casinos that the Petitioners gambled in during those
years, except for Harrah’s.”
8As we understand the way in which petitioners calculated
their claimed gambling losses at Harrah’s, petitioners multiplied
the number of minutes between gambling winnings at a $100 slot
machine or a $25 slot machine, as reflected on the respective
Harrah’s substitute Forms W-2G with respect to Aug. 13 and 14 and
Sept. 4, 1999, by the amount that they estimated they would have
been able to wager within a minute in such a $100 slot machine or
such a $25 slot machine if they had played two coins at one time.
Mr. Hartsock testified that he would have been able to wager
within a minute $1,200, “give or take $200”, in a $100 slot
machine and $300 in a $25 slot machine. Mr. Hartsock testified
that petitioners reduced the amount so calculated to reflect that
they would not have been constantly wagering in slot machines
that they were playing because they would have stopped wagering
to light up cigarettes, get drinks, or talk with others.
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