Thomas Patrick and Christine E. Dawson - Page 3




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               Respondent determined a $4,190 deficiency in petitioners’              
          Federal income tax for 2004 and an $838 accuracy-related penalty            
          under section 6662 due to negligence.                                       
               The issues for decision are whether petitioners are entitled           
          to net their gambling losses against their gambling winnings in             
          computing adjusted gross income and whether they are liable for a           
          section 6662(a) accuracy-related penalty due to negligence.                 
                                     Background                                       
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated by this reference.  Petitioners resided in                     
          Williamstown, New Jersey, at the time they filed their petition.            
               During 2004, petitioner Thomas Dawson was employed full time           
          as a building inspector, and petitioner Christine Dawson was                
          employed full time as a registered nurse.                                   
               During 2004, petitioners gambled at casinos in Atlantic                
          City, New Jersey.  Most of petitioners’ gambling consisted of               
          playing $5- or $10-pull slot machines.  Neither petitioner was a            
          professional gambler.  Their combined jackpots received from                
          Atlantic City casinos in 2004 totaled $208,420; however, their              
          combined gambling losses for 2004 exceeded the $208,420 jackpots            
          that they won.  In other words, petitioners’ gambling activities            
          during 2004 resulted in a net loss.                                         








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