The taxpayer had substantial losses from gambling activities, but the IRS denied any related deductions due to lack of records. The taxpayer did not maintain records of gambling winnings and losses, did not testify, and failed to provide evidence of tickets, receipts logs, canceled checks, etc. The Tax Court determined that it could not estimate the taxpayer's gambling losses because the taxpayer failed to establish the entitlement to any deductions. On appeal, the court affirmed on the basis that the Tax Court did not err in finding that that taxpayer's evidence (consisting of unexplained, non-contemporaneous documentation) was insufficient to substantiate his claim that he was entitled to deductions for gambling losses. Similarly, the appellate court held that the Tax Court did not err in refusing to estimate the taxpayer's gambling losses because the taxpayer failed to establish entitlement to any deduction at all. Rios v. Comr., No. 12-72440, 2014 U.S. App. LEXIS 22190 (9th Cir. Nov. 24, 2014), aff'g., T.C. Memo. 2012-128.