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Zenaida became a pit boss at some point and an assistant to the
president of the CIPAA Casino at a later point.
1. Hourly Compensation
Rogelio worked 882.5 hours at the casino premises in 1991,
for which the CIPAA Casino paid $8,825 of hourly compensation to
him. Zenaida worked 105.5 hours at the casino premises in 1991,
for which the CIPAA Casino paid $1,055 of hourly compensation to
her. Petitioners did not report any of their CIPAA Casino hourly
compensation on their 1991 tax return.
Rogelio worked 947.5 hours in 1992, for which the CIPAA
Casino paid hourly compensation to him.3 Zenaida worked 654.75
hours in 1992, for which the CIPAA Casino paid $6,548 (rounded)
of hourly compensation to her. Petitioners did not report any of
their CIPAA Casino hourly compensation on their 1992 tax return.
The CIPAA Casino paid $8,110.75 of compensation income to
Rogelio for 1993. The CIPAA Casino paid $5,781.79 of
3On opening brief, respondent asks us to find that Rogelio
was a dealer in 1992, “and in 1993 casino management promoted him
to pit boss.” On the same page of this brief, respondent asks us
to find that Rogelio was paid “$12 an hour as a pit boss in
1992.” Petitioners do not object to either proposed finding.
The parties agree that the CIPAA Casino compensated Rogelio at
the rate of $10 per hour when he was a dealer and $12 per hour
when he was a pit boss. Because each party is on both sides of
the question as to when Rogelio was shifted from $10 per hour to
$12 per hour, the parties are directed to resolve this matter in
the computation under Rule 155.
Unless indicated otherwise, all Rule references are to the
Tax Court Rules of Practice and Procedure.
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