Thomas Patrick and Christine E. Dawson - Page 4




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               On their 2004 Federal income tax return, petitioners                   
          reported adjusted gross income of $145,694 which did not include            
          any of the jackpots.  Petitioners did not claim deductions on               
          their 2004 return for any of their gambling losses.  Petitioners            
          did not report their gambling jackpots and losses because their             
          gambling activities failed to produce net winnings in 2004.                 
               After examining petitioners’ 2004 return, respondent                   
          determined that petitioners’ casino jackpots were gambling                  
          winnings and increased petitioners’ adjusted gross income by                
          $208,420.  Respondent also determined that petitioners were                 
          entitled to itemized deductions for gambling losses of $208,420.            
               While respondent allowed itemized deductions for gambling              
          losses in the same amount that he increased petitioners’ adjusted           
          gross income, the increase in adjusted gross income triggered               
          certain limitations on other deductions.  As a result, respondent           
          disallowed a $490 tuition deduction, disallowed job-related and             
          miscellaneous expenses of $4,178, decreased total itemized                  
          deductions by $6,267, and disallowed a $6,200 deduction for                 
          personal exemptions.  These adjustments, based on respondent’s              
          adjustment to petitioners’ adjusted gross income, are                       
          computational adjustments required by law.                                  
               In their petition, petitioners claim that it makes no sense            
          to increase their adjusted gross income because their gambling              








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