Robert K. and Cheryl Hardwick - Page 7

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          and had a net loss of $14,141 for 2002.  The Grand Casino Tunica            
          win-loss statement for Mr. Hardwick reflects that he won $21,320,           
          and lost $6,420, for net winnings of $14,900 for 2002.  Overall,            
          the win-loss statements reflect that petitioners had a net loss             
          of $194 for 2002 for gambling activity recorded by their Players’           
          Club cards.                                                                 
               On their 2002 joint Form 1040, U.S. Individual Income Tax              
          Return, which was prepared by petitioners’ accountant, Ben                  
          Shillaci, petitioners reported total gambling winnings of                   
          $308,400.  Petitioners now concede that their total gambling                
          winnings for 2002 were actually $322,500.  See supra note 1.                
          Petitioners’ gambling winnings consisted of $26,500 from the Beau           
          Rivage Resort, Inc., $80,350 from the Grand Casino Tunica, and              
          $215,6507 from the Grand Casino Biloxi.  In addition, petitioners           
          had gambling winnings in excess of the amounts reported on Forms            

               7The parties stipulated that petitioners had gambling                  
          winnings of $215,650 from the Grand Casino Biloxi for 2002.                 
          However, the 2002 Form W-2G, Certain Gambling Winnings, issued by           
          the Grand Casino Biloxi that was admitted into evidence as                  
          exhibit 11-R, reflects that petitioners had $200,250 in gambling            
          winnings.  It is possible that petitioners stipulated gambling              
          winnings from the Grand Casino Biloxi in excess of the amount               
          shown on the 2002 Form W-2G, and that the $215,650 stipulated               
          amount includes multiple jackpot winnings that were less than               
          $1,200 (and therefore not reflected on the Form W-2G).                      
               The $322,500 amount that petitioners concede is the total              
          amount of their gambling winnings for 2002 appears to be based on           
          the stipulated $215,650 amount, and not on the $200,250 amount              
          reflected on the Grand Casino Biloxi 2002 Form W-2G.  It is                 
          possible that the $322,500 amount reflects the net increase of              
          $14,100 in petitioners’ gambling winnings over the $308,400 they            
          reported on their 2002 joint Form 1040.  See supra note 1.                  

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