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masseuse offsets the fact that petitioners paid the masseuse her
one-half in cash.3
d. Masseuses' Average Earnings
Petitioners contend that respondent determined that
petitioners received more income from the Tokyo Saunas than the
total amount the masseuses earned, which petitioners contend
shows that respondent's determination is in error since
petitioners and the masseuses each got one-half of the payments.
Petitioners based this contention on the assumption that there
were 7 masseuses in 1983, 8 in 1984, 10 in 1985, 9 in 1986, and 6
in 1987, and based on what petitioners claim to be a high average
of $36,000 per year per masseuse. We disagree. Petitioners'
approach is accurate only if petitioners' assumption about the
number of masseuses and their average income is accurate. No
reliable records are available that show how many masseuses
worked at the saunas. Petitioner-husband testified that they had
six masseuses in 1983. On brief, petitioners estimate that they
had seven masseuses in 1983. The unburned daily sheets show that
they had 10 masseuses in November 1983. Petitioner-husband
testified that one to five masseuses worked at each sauna at any
given time.
3 Petitioners do not contend that Tokyo Saunas paid a
significant amount of credit card merchant fees.
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