T.C. Memo. 2001-73
UNITED STATES TAX COURT
ROGELIO R. BALOT and ZENAIDA V. BALOT, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19077-98. Filed March 23, 2001.
Ps worked as blackjack and roulette dealers, and P-H
worked as a “pit boss”, at a casino in Prince George’s
County, Maryland. The casino recorded on daily time sheets
the number of hours Ps worked. Also, the casino gathered,
apportioned, and periodically paid to the dealers and pit
bosses the tips from the patrons. R determined deficiencies
based on the casino’s time sheets and other records, and Ps’
bank deposits.
1. Held: Ps are liable for additions to tax for civil
fraud for 1991 and 1992. See sec. 6663, I.R.C. 1986.
2. Held, further, Ps are liable for an addition to tax
for negligence for 1993. See sec. 6662(a), I.R.C. 1986.
3. Held, further, amounts of deficiencies
redetermined.
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011