- 12 - petitioners rely on, inter alia, certain workpapers that they prepared and that purport to show how they calculated the gam- bling losses that they contend they incurred at Harrah’s during 1999. We have serious reservations about the reliability of the self-serving and uncorroborated workpapers on which petitioners rely.9 We also have serious reservations about the reliability 9For example, one of the workpapers that petitioners pre- pared purports to show their estimate of the gambling losses that they incurred at Harrah’s on Aug. 13 and 14, 1999. The total gambling winnings shown on that workpaper for those dates are different from the total gambling winnings shown (1) on the respective Harrah’s substitute Forms W-2G with respect to those dates and (2) on another workpaper that petitioners prepared and that purports to show the total of petitioners’ gambling winnings at Harrah’s on Aug. 13 and 14, 1999, as reflected on such respec- tive forms with respect to Aug. 13 and 14, 1999, as well as other gambling winnings that petitioners claim they had at Harrah’s on such dates and that are not reflected on such respective forms. Moreover, one of the workpapers that petitioners prepared purports to show their estimate of the gambling losses that they incurred at Harrah’s on Sept. 4, 1999. The total gambling winnings shown on that workpaper for that date are different from the total gambling winnings shown on (1) Harrah’s substitute Form W-2G with respect to Sept. 4, 1999, and (2) on another workpaper that petitioners prepared and that purports to show the total of petitioners’ gambling winnings at Harrah’s on Sept. 4, 1999, as reflected on Harrah’s substitute Form W-2G with respect to that date, as well as other gambling winnings that petitioners claim they had at Harrah’s on such date and that are not reflected on such form. Another example of the unreliability of petitioners’ workpapers is that one of those workpapers indicates that peti- tioners estimated that Mr. Hartsock wagered in a $25 slot ma- chine, and lost before any reduction for time spent not wagering, $22,800 during what they computed to be a 19-minute period between 10:22 p.m. and 10:51 p.m. on Aug. 14, 1999. However, the (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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