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compensation income to Zenaida for 1993. The CIPAA Casino issued
Forms W-2 to Rogelio and Zenaida for this 1993 compensation
income, which petitioners reported on their 1993 tax return.4
2. Tip Income
Each petitioner received a share of the tips that bettors
left at the tables in the casino premises during each of the
years in issue. On their 1992 tax return, petitioners reported
that Rogelio received $750 tip income and Zenaida received $480
tip income. Petitioners’ 1991 and 1993 tax returns do not
include any income that is stated to be tip income. Petitioners
did not report any income from the CIPAA Casino on their 1991 tax
return. The income from the CIPAA Casino that petitioners
reported on their 1993 tax return is shown on Forms W-2, but is
not described as including tip income, on either the Forms W-2 or
petitioners’ tax return.
4The four Forms W-2 attached to petitioners’ 1993 tax return
show “Wages, tips, other compensation” amounts aggregating
$71,146.57. On their tax return, petitioners show $71,237. The
difference is accounted for by (1) rounding and (2) petitioners’
reporting Zenaida’s CIPAA Casino income as $5,872, instead of
$5,781.79, as shown on the Form W-2. This roughly $90
overreporting is to be corrected in the computation under Rule
155, to the extent it has not already been indirectly taken into
account in respondent’s notice of deficiency determination of
“Other Unreported Income”.
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Last modified: May 25, 2011