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resulting number and multiply it by the number of points for each
employee to arrive at that employee's total gross receipts for
the shift. For example, if 3 captains (30 points), 8 waiters and
waitresses (64 points), and 3 busboys (15 points) worked a shift,
the total would be 109 points. If the restaurant made $5,000 in
gross receipts that shift, $45.87 ($5,000 divided by 109) would
be allocated for each point. Thus, a waiter or waitress would be
allocated gross receipts of $366.96 ($45.87 times 8 points) for
that shift by Mr. Patel.
Based on the tip allocation spreadsheets prepared by Mr.
Patel, the rounded-off percentage of gross receipts attributed to
petitioner by Sandomenico was approximately 5 percent for 1989,
and approximately 7 percent for 1990.
Respondent determined petitioner had $26,511 and $21,396 of
unreported tip income for 1989 and 1990, respectively, using the
following method. For each year in issue, respondent multiplied
the total charged tip amount from Sandomenico's Form 8027 by the
percentage of total gross receipts Sandomenico attributed to
petitioner. From this figure, respondent subtracted the tip
amount petitioner reported on her return. This was the amount
respondent determined was unreported charged tip income for
petitioner. Cash tips were figured by subtracting the total
charged receipts from the gross receipts reported on
Sandomenico's Form 8027, which resulted in the total cash
receipts amount. Respondent then multiplied this figure by 12
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