Stu,

my statement was not incorrect. Most people talk about winnings as being taxable only if their is W2G or 1099. You might not want to accept that fact it is correct, if you spend any significant time around gamblers you will soon see that it is in fact true. And in fact few people report their gambling winnings unless there is W2G or 1099 and everyone here accpet you seems to knwo that this is true.

As far as Mr. Perlowski addressing my arguments, I understand that he is busy with aproject right now. but when he is not busy I am always happy to talk with him.

The bottom line is that my argument is logically consistent. I recognize that logically consistent arguments do not always in Tax or legal matters. That doesn't make the arguemnt ludicris.

In fact I suspect that the reason you do not address the argument is that you see that if you follow the argument logically you will ultimately have to put form over substance to support the idea that a satellite win is taxable. Ultimately their is nothing subnstantively different between my sceanrios 2 and 3, and the sole difference becomes the name applied. and the only difference between these scenarios and scenario 1 is that in scenario 2 and 3 additional players may join in. But there really doesn't seem to be any logical basis to alter the tax treatment of the situation based on whether additional players may join in at a later stage.

Quite honestly it seems a bit intellectually dishonest to dismiss my position as "ludicris" without actually addressing the argument.

So even if you don't want to address my hypotheticals and follow the argument logically, tell me why the argument that the Main Event is simply a continuation of the satellite (in the case where the satellite is held at the same casino and the satellite winnings are nontransferable/nonrefundable/no cash value) is ludicris.

Second are you aware of any rulings/decisons that address this argument.