Plaintiff David Zarin was a compulsive gambler who gambled on credit at the Resorts International Casino in Atlantic City, accumulating losses totaling $3,435,000. After litigation was commenced by Resorts against Mr. Zarin, he agreed to pay $500,000 in full settlement of the entire $3,435,000 claim.
Thereafter, the Internal Revenue Service (IRS) issued a Notice of Deficiency claiming the plaintiff's gambling on credit resulted in $3,435,000 of income in 1980 from...
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