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393 (1979); McGee v. Commissioner, 61 T.C. 249, 256-257 (1973),
affd. 519 F.2d 1121 (5th Cir. 1975). This intent may be inferred
from circumstantial evidence. See Powell v. Granquist, 252 F.2d
at 61; Gajewski v. Commissioner, 67 T.C. 181, 200 (1976), affd.
without published opinion 578 F.2d 1383 (8th Cir. 1978),
including the implausibility of petitioners’ explanations. See
Bradford v. Commissioner, 796 F.2d 303, 307 (9th Cir. 1986) (and
cases cited therein), affg. T.C. Memo. 1984-601; Boyett v.
Commissioner, 204 F.2d 205, 208 (5th Cir. 1953), affg. a
Memorandum Opinion of this Court dated Mar. 14, 1951. Fraud is
not imputed from one spouse to another; in the case of a joint
tax return, respondent must prove fraud as to each spouse charged
with liability for the addition to tax. See sec. 6663(c); Hicks
Co. v. Commissioner, 56 T.C. 982, 1030 (1971), affd. 470 F.2d 87
(1st Cir. 1972); Stone v. Commissioner, 56 T.C. at 227-228.
A. Underpayment
1. The CIPAA Casino--Hourly Compensation
Time sheets were maintained by the CIPAA Casino for dealers
and others who worked at the casino during each of the years
before the Court. The CIPAA Casino paid compensation of $10 per
hour to dealers and $12 per hour to pit bosses during these
years.
Each petitioner worked at the casino in 1991 and in 1992 and
received, as compensation for his or her services, weekly
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