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COLEMAN v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 19540-17.

T.C. Memo. 2020-146

JOHN M. COLEMAN, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed October 22, 2020.

Attorney(s) appearing for the Case

John B. Magee and Eric J. Albers-Fiedler , for petitioner.

William J. Gregg , Bartholomew Cirenza , and Ryan Z. Sarazin , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

Because petitioner did not file a Federal income tax return for 2014, the IRS prepared a substitute for return (SFR) and issued him a notice of deficiency. The parties have settled all issues but two: (1) whether petitioner has substantiated gambling losses in excess of $350,241, the...

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