Cesanelli v. Commissioner
United States Tax Court
1. Respondent's determination that petitioners, waiters in a restaurant, received income as tips in an amount equal to 10 per cent of sales to patrons, sustained. 2. Charge of fraud to evade taxes sustained.
1Opinion of the Court
OPINION.
Van Fossan, Judge:
The respondent determined deficiencies and penalties against the several petitioners, as follows:
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The parties stipulated substantially as follows:
As used in this opinion, the term “petitioners” refers only to Naz-zareno D. Cesanelli, Carlo Baletta, Rudolph Frey, Felice Genardini, Julius Tosch, and Eugene A. Holtz, and not to the wives of any of them unless otherwise specifically stated.
All the petitioners herein were employed as waiters at Solari’s Grill, a restaurant at. 354 Geary Street, San Francisco, California, and received income in the form of…
2Cited by8 opinions
- Roberts v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1949
- Roberts v. CommissionerUnited States Tax Court · 1948
- Caldwell v. CommissionerUnited States Tax Court · 1966
- Cesanelli v. CommissionerUnited States Tax Court · 1947
- Kruzic v. CommissionerUnited States Tax Court · 1979
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