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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petitioners had large sums of money being deposited and withdrawn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.
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