-3- incorporated by this reference. Petitioners resided in Eden Prairie, Minnesota, at the time they filed the petitions. Petitioners are married and were married during the years at issue. Petitioners filed the tax returns for the years at issue as married filing separately. Mr. Paterson’s Bookmaking Activities Mr. Paterson stipulated that he has been a professional bookmaker for about 20 years including the years at issue. Mr. Paterson has a criminal history. He was convicted of tax evasion in 1979. He also recently pleaded guilty to another criminal fraud charge relating to Form 730, Tax on Wagering, that he filed for years other than the years at issue. Mr. Paterson expected at the time of trial that he might have to serve time for these criminal offenses. Mr. Paterson conducted his illegal activities with two sons from a previous marriage. The three of them took bets at one son’s apartment in Eden Prairie, Minnesota. The primary assets of the bookmaking enterprise were three cellular phones. Mr. Paterson had no credit history because he dealt solely in cash and had no credit card, so Mrs. Paterson obtained them in her name. Mr. Paterson’s customers called these phones to place bets. Mr. Paterson had between 50 and 75 regular customers who bet with him. These customers bet on college and professional football and usually called Mr. Paterson to bet on Saturdays and Sundays, the highest volume days. Mr. Paterson charged hisPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007