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Unlike Doffin, this is not a case where the petitioners have
few assets and no income apart from gambling. Mr. Hardwick is
president and part owner of Hardwick Co. Petitioners reported
$391,546 in taxable income for 2002 aside from their $308,400
reported gambling winnings.9 Further, respondent has allowed
petitioners a $170,215 deduction for gambling losses for 2002
based on their submitted records, which is far more generous than
the $494 deduction the Commissioner allowed the taxpayer in
Doffin. The Court notes that the losses reported by the casinos
as recorded on petitioners’ Players’ Club cards total $115,336.
The records that petitioners presented at trial are
incomplete. The win-loss statements issued by the Grand Casino
Biloxi and the Grand Casino Tunica do not include at least two
gambling trips that petitioners made to Mississippi on March 2
and April 6 and 7, 2002. Mr. Hardwick’s log does not include at
least one substantial win by petitioners in the amount of
$24,000, and appears to carry over a net gambling loss from 2001
to 2002. See supra note 4. Additionally, the Forms W-2G issued
by the casinos do not include winnings under $1,200, which
winnings petitioners failed to keep track of and record on their
own. Petitioners’ line of credit statements reflect that $50,500
in markers was debited in 2002. However, the mere fact of
9Petitioners reported total taxable income of $699,946 on
their 2002 Federal income tax return, of which $308,400 was their
reported gambling winnings.
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