- 23 - worked in the casino. Petitioners’ only contentions with regard to this hourly “remuneration” (petitioners’ term) are that (1) it was not “wages”, and (2) “The management of the CIPAA casino inflated the number of hours worked by casino employees during the years 1991-1993.” Firstly, none of this hourly compensation was reported on petitioners’ tax returns for 1991 and 1992.9 As a result, petitioners’ allegation that the management of the CIPAA Casino inflated the number of hours worked by casino employees does not affect our conclusion that petitioners’ failures to report any of their hourly compensation result in underpayments of tax for both 1991 and 1992. Secondly, the CIPAA Casino time sheets appear to conform to the testimony of each petitioner, both as to the procedures that were followed and also as to each petitioner’s pattern of arrivals at and departures from the casino. The variety of handwritings confirms the testimony that often the entries for 9Petitioners reported on their 1992 tax return $750 tip income for Rogelio and $480 tip income for Zenaida. The parties stipulated that “Petitioners typically worked on Saturdays and at least one day during the week.” If these tips were the hourly compensation (as petitioners seem to suggest), and if petitioners were paid $10 or more per hour (as petitioners concede), then this would mean that Rogelio worked for an average of less than 1 hour each day he showed up, and Zenaida worked for about � hour each day she showed up. The absurdity of this conclusion convinces us that petitioners do not seriously contend that their 1992 tip reporting was intended to be a reporting of the hourly compensation that each petitioner received from the CIPAA Casino.Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
Last modified: May 25, 2011