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respondent’s three witnesses seek revenge against petitioner
because their services in the gaming operation were discontinued.
We find this attempt unavailing. Given that none of respondent’s
three witnesses reported her receipt of the $65 cash payments as
income, we do not believe that they simply out of revenge
testified against their self-interests by admitting clearly and
under oath that they received the $65 payments and knowingly did
not report those payments as income.
In addition to its witnesses, petitioner relies upon
approximately 29 affidavits contained in the administrative
record. These affidavits, which were mostly signed in bulk in
June or September of 1997 and were submitted to respondent during
the audit, were from various workers of petitioner and stated
that the affiant was not paid for his or her services in the
gaming operation. We are unpersuaded by these affidavits, and we
give them no weight. The affiants included 12 workers of
petitioner who did not work for petitioner during the relevant
years and 4 of petitioner’s officers (including Clausing,
Carroll, and Whitaker). Many of the affiants did not testify at
trial so as to be subject to our determination of their
credibility or to questioning as to the circumstances under which
they signed or otherwise acquiesced in the statements contained
in the affidavits. As to the affidavits, most of them were
written pro forma on petitioner’s letterhead and were prepared by
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