- 13 - borrowing, represented here by marker debit transactions, does not substantiate actual losses of those borrowed funds on gambling. Schooler v. Commissioner, supra at 870. Overall, there does not appear to be a correlation between the win-loss statements, petitioners’ Forms W-2G, Mr. Hardwick’s log, and petitioners’ bank account statements. Notably, the win- loss statements reflect that petitioners had gambling winnings totaling $115,142, while the Forms W-2G provide that petitioners had total gambling winnings of $322,50010. Petitioners have not accounted for the $207,358 difference in gambling winnings between the win-loss statements and Forms W-2G. At trial, Mr. Hardwick was unsure of petitioners’ total dollar amount of gambling winnings or losses, explaining that he only kept track of their net amount won or lost. Petitioners’ bank account statements reflect that petitioners had large sums of money being deposited and withdrawn on a monthly basis, and there does not appear to be a correlation between petitioners’ monthly bank account balance and any substantial gambling win or loss in 2002. For example, according to Mr. Hardwick’s log, petitioners lost $25,000 in February 2002, yet their bank account balance increased by approximately $33,000 for the month of February. This might reflect the 30 to 45 day 10This amount is based on the parties’ stipulations. See supra note 7.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 NextLast modified: March 27, 2008