Rogelio R. Balot and Zenaida V. Balot - Page 35




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          there may have been unreported income for later years.  This,               
          alone, is sufficient to warrant the use of the bank deposits                
          method to determine how much 1991 income was unreported and to              
          test the comprehensiveness of petitioners’ income reporting for             
          later years.                                                                




               13(...continued)                                                       
                    A    Uh-huh.                                                      
                    Q    Okay.  Did you tell them how much income you                 
               earned at the casino?                                                  
                    A    As far as my recollection, as far as ‘91 because             
               we were just talking about it, I remember I told him that              
               these are tips.                                                        
                    Q    You told him what?                                           
                    A    When -- in 1991, I remember I was -- you know, I             
               don’t know.  Best of my recollection, I thought I told my              
               accountant or the tax preparer that this is how much money I           
               made in the casino.                                                    
                    Q    But you didn’t provide that return preparer with             
               any books and records reflecting the amount of tips and                
               wages that you earned at the casino during 1991 through                
               1993, right?                                                           
                    A    No.  We just -- just like I said, I never kept a             
               record.                                                                
                           *    *    *    *    *    *    *                            
                    Q    [Cohen] Did you keep any books and records related           
               to the income that you earned with the casino back in the              
               years at issue?                                                        
                    A    [Zenaida] No, I did not.  I should have, but I did           
               not.                                                                   






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