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B. Fraudulent Intent
Each day that either petitioner worked in the casino, that
petitioner earned $10 (or $12) per hour for the time worked.
Each week, the CIPAA Casino paid to each petitioner (and to their
coworkers at the casino) the hourly compensation. These hourly
compensation amounts paid to petitioners totaled almost $10,000
in 1991 and around $15,000 in 1992. Petitioners failed to report
any part of this hourly compensation on their 1991 and 1992 tax
returns. They also failed to report any of their 1991 tip
income. The foregoing omitted income amounts to about 15 percent
in comparison to the total income they reported on their 1991 tax
return, and about 20 percent for 1992. See supra table 3. Based
on the record as a whole, including our observations of each
petitioner at trial (both testified) and our evaluation of their
educational backgrounds and the sort of full-time jobs each of
them had during 1991 and 1992, we conclude that each petitioner
knew that this hourly compensation and tip income were subject to
tax and that their failures to report any part of this income on
either of their tax returns for 1991 and 1992 were due to fraud.
Thus the underpayments resulting from these failures to report
were due to fraud. We have so found.
11(...continued)
or any quantification of petitioners’ tip income.
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