- 13 - of the methodology that petitioners contend they used, as re- flected on such workpapers, to estimate the gambling losses that they claim they incurred at Harrah’s on August 13 and 14 and September 4, 1999.10 We are unwilling to rely on Mr. Hartsock’s self-serving and uncorroborated testimony and the self-serving and uncorroborated workpapers that petitioners prepared in order to establish that they incurred gambling losses at Harrah’s on certain dates during 1999. Petitioners presented no evidence in 9(...continued) time interval between 10:22 p.m. and 10:51 p.m. is 29 minutes, not 19 minutes. Moreover, Mr. Hartsock testified that he would have been able to wager within a minute only $300 in a $25 slot machine, or at most $5,700 in a 19-minute period and at most $8,700 in a 29-minute period. An additional example of the unreliability of petitioners’ workpapers is that one of those workpapers indicates that peti- tioners estimated that Mr. Hartsock wagered in a $100 slot machine, and lost before any reduction for time spent not wager- ing, $42,000 during what they computed to be a 35-minute period between 1:35 a.m. and 2:00 a.m. on Sept. 5, 1999. However, the time interval between 1:35 a.m. and 2:00 a.m. is 25 minutes, not 35 minutes. 10For example, petitioners have failed to establish that they gambled during each time interval between gambling winnings shown on the respective Harrah’s substitute Forms W-2G with respect to Aug. 13 and 14 and Sept. 4, 1999, at the same slot machine from which they received gambling winnings at the end of each such time interval, as shown on such forms. Nor have petitioners persuaded us that they would have been able to wager within a minute the respective amounts that they claim they wagered in a $100 slot machine (i.e., $1,200) and a $25 slot machine (i.e., $300). In addition, petitioners did not provide a specific and acceptable explanation as to how they calculated the respective amounts of time that they assert they did not spend playing slot machines to smoke cigarettes, get drinks, and talk with others, which time they assert they used to reduce their claimed gambling losses at Harrah’s.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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