Robert K. and Cheryl Hardwick - Page 14
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float delay in covering markers, but there was no credible
evidence explaining these discrepancies.
The record provides no satisfactory basis for estimating
petitioners’ gambling losses in excess of the $170,215 allowed by
respondent. See Stein v. Commissioner, supra. There are too
many omissions and discrepancies among the documents petitioners
have presented as substantiation. Consequently, the Court will
not apply the Cohan rule to estimate the amount of petitioners’
gambling losses. Petitioners could have avoided this result by
keeping complete records of their gambling activities or perhaps
by simply using their Players’ Club cards to track their slot
machine play on each of their gambling trips.
The Court has considered all of petitioners’ contentions,
arguments, requests, and statements. To the extent not discussed
herein, the Court concludes that they are meritless, moot, or
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: March 27, 2008