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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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