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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