- 2 -
decision is whether petitioner is entitled to deduct gambling
losses in excess of the $127,165 that respondent conceded for
2002.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
herein by this reference. At the time she filed her petition,
petitioner resided in Blaine, Minnesota.
Petitioner is a recreational gambler who played slot
machines regularly in 2002. Petitioner visited the casino on a
weekly basis and played the slots for hours at a time. When
petitioner won a jackpot, she would often use her winnings to
play at a higher stakes slot machine. Petitioner kept no diary,
log, or record of any kind of her gambling winnings and losses.
In her 2002 Form 1040, U.S. Individual Income Tax Return,
filed in April 2006, petitioner reported gambling winnings and
losses of $21,051. Petitioner subsequently filed a Form 1040X,
Amended U.S. Individual Income Tax Return, in which she reported
gambling winnings and losses of $244,744. Petitioner now
concedes that her total gambling winnings for 2002 were actually
$265,795.
Respondent issued a notice of deficiency on October 6, 2006,
disallowing $223,693 of petitioner’s claimed $244,744 gambling
losses due to lack of substantiation. Petitioner filed a timely
Page: Previous 1 2 3 4 5 6 Next
Last modified: March 27, 2008