Robert K. and Cheryl Hardwick - Page 12

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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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