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Petitioner also contends that net sales may include room
service sales and hospitality sales. However, that contention is
contrary to the parties’ stipulation that petitioner’s net sales
from the room service function were $61,427.78. Further, the
parties’ stipulation appears to be consistent with the underlying
exhibit, which specifies “room service” only and not room service
and hospitality. In any event, petitioner’s contention is
unavailing because respondent’s deficiency determination is
structured as though petitioner’s net sales were derived from
both the room service function and the hospitality function. In
other words, in determining unreported tips, respondent
subtracted reported tips of $5,153 (per petitioner’s Form W-2)
from tips as reconstructed based on petitioner’s net sales of
$61,427.78 and not based on net sales of some greater amount.
Petitioner also makes various arguments about the physical
location of the Las Vegas Hilton and the demographics of the
hotel’s clientele. However, given the fact that respondent’s
determination was based on data furnished by the Las Vegas Hilton
that was specifically applicable to its room service department,
and not on data from other hotels or other departments,
petitioner’s arguments are unavailing.
Finally, although we are not persuaded by any of
petitioner’s arguments, we think respondent’s reconstruction of
petitioner’s tip income is deficient in one regard. As
previously found, he did not pool or share his tips with other
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