-10-
kept half of the gross receipts or that petitioners did not
report all of their gross receipts to her.
Petitioner-husband signed, and directed each masseuse to
sign, papers showing that masseuses were paid about $200 a week.
Petitioner-husband told the masseuses to give those payroll
papers to Amoroso. Petitioners issued Forms W-2 showing that
each masseuse earned substantially less than petitioners knew
they earned. Petitioners withheld a fixed amount of taxes from
the masseuses regardless of the amount they earned.
D. The Daily Sheets Kil Lee Gave to Respondent
In November 1987, Kil Lee found four sets of daily sheets
that he had not burned and gave them to respondent. Those daily
sheets show the following:
Number Number of
Tokyo Sauna Dates of days masseuses Gross receipts
Joplin 10/29/83- 35 5 $42,696
12/2/83
Springfield 10/29/83- 35 5 39,030
12/2/83
Billings 3/28/87- 28 3 25,700
4/24/87
Springfield 3/28/87- 28 5 50,306
4/24/87
E. Petitioners' Net Worth
1. Overview
Petitioners concede that respondent computed their net worth
correctly except for the amount of their cash on hand on December
31, 1982, 1983, 1984, 1985, 1986, and 1987.
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