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1 The $62,339 total includes petitioners’ Form W-2 income from
First American Bank and Validity Corporation, and
petitioners’ “Unreported Tip Income” from the CIPAA Casino
(Rogelio--$750; Zenaida--$480).
2 Comparison of a schedule attached to petitioners’ 1993 tax
return and the Forms W-2 attached to the same return makes
it clear that a transposition of two digits from Zenaida’s
CIPAA Casino Form W-2 to the schedule resulted in
petitioners overstating their income by $90. See supra
note 4.
3 Petitioners’ 1992 tax return shows a $19,000 capital loss
carryover from 1992 to 1993, stemming primarily from a
$21,688 “Loss in value” on 12,000 shares of PanAm Stock
acquired on November 26, 1990. It does not appear that
petitioners claimed any capital loss carryover on their 1993
tax return.
Petitioners timely filed their tax returns for each of the
years in issue: 1991--mid-April 1992, 1992--mid-August 1993, and
1993--mid-April 1994.
Petitioners’ 1991 and 1992 tax returns were prepared by W.O.
Monroyo & Associates. Petitioners’ 1993 tax return was prepared
by Automated Tax & Financial Services.
____________________________
Petitioners failed to report on their tax returns the hourly
compensation that the CIPAA Casino paid to each of them in 1991
and 1992. Petitioners failed to report on their tax return the
tip income that the CIPAA Casino gathered, apportioned, and
periodically paid to petitioners in 1991. The failures to report
this income resulted in underpayments of tax required to be shown
on petitioners’ tax returns for 1991 and 1992. The failures to
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