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any individual were made by that individual. Rogelio testified
that his usual Saturday shift was 14 hours--from noon to 2 a.m.
the next morning, confirming the information on the time sheets.
Zenaida testified to her usual 14-hour Saturday shift. As to
Tuesdays, Rogelio’s confusing testimony appears to confirm the
general 11-hour shift shown by the time sheets; Zenaida clearly
testified that her Tuesday shift was generally around 6 hours.
As a result, we are satisfied that the CIPAA Casino time sheets
are accurate as to the number of hours each petitioner worked at
the casino in 1991 and 1992.
Thirdly, as petitioners implicitly conceded by reporting
tips as income on their 1992 tax return, tips are income subject
to tax. See, e.g., Olk v. United States, 536 F.2d 876, 879 (9th
Cir. 1976). So that “he that runs may read”, line 7 of the Form
1040 for each of the years before the Court states “Wages,
salaries, tips, etc.” (Emphasis added.) Whatever label
petitioners would rather we apply to the hourly compensation that
the CIPAA Casino paid to each petitioner in 1991 and 1992, those
payments are income subject to tax. See, e.g., section 61(a)(1).
We hold, for respondent, that respondent has proven by clear
and convincing evidence that petitioners failed to report the
hourly compensation paid to them by the CIPAA Casino in 1991 and
1992, in the amounts determined in the notice of deficiency as
“Unreported Income-Casino”, except to the extent that
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