Rogelio R. Balot and Zenaida V. Balot - Page 21




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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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