Fortunately for Jacob Bright, Docket No. 10095-22, filed 5/4/23, though his recordkeeping was defective, and the bespoke preparer to whom he turned for his unreviewed return for year at issue shunted Jake’s return to the preparer’s daughter, who was better at fiction than tax preparation, Jake hits the jackpot when Judge Ronald L. (“Ingenuity”) Buch takes Jake’s case.

Judge Ingenuity Buch, with diligence exemplified by such a distinguished career as his, and ingenuity that can only be applauded, wades through W-2Gs, and miscellaneous receipts from such high-class venues as Mystic Lake Casino, Treasure Island Resort and Casino in Minnesota, and Diamond Jo Worth Casino in Iowa. Transcript, at p. 4.

Jake gambled to supplement his income as a storm damage repairer, with the usual result. “His bank account records show that his account frequently had a low or negative balance in [year at issue]. Mr.  Bright recognizes and regrets the negative effect that gambling has had on his life.” Transcript, at p. 4.

Judge Buch wades through casino records, even though recognizing that slot wins below $1200 don’t make it onto the tallies. Jake was primarily a slotshot, the worst form of gambler, though he did bet sports and blackjack.

Out of the morass, Judge Ingenuity Buch finds the path trod by the Cohanim.

“Although the casino records do not capture the full picture, they provide a sufficient basis upon which we can make an estimate.  Because each casino’s records report Mr. Bright’s activity in a different way, our estimation method differs per casino.” Transcript, at p. 12.

At close of play, Jake is stuck with the winnings the preparer’s daughter put on the return he didn’t review, but he has $191,756 of losses allowed, and IRS drops the Section 6662 chops.

I know it would be shockingly illegal and Judge Buch would never think of it, but if Jake tips the dealers and the servers at the casinos, he should definitely tip out Judge Buch. Or maybe make an appropriate charitable donation. And join GA: twelve steps save lives.