- 21 - 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, weeklyPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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