Rogelio R. Balot and Zenaida V. Balot - Page 23




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          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.           





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