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record does not show that either petitioner received any such
direct tips.
D. Petitioners’ Involvement With the CIPAA Casino
Rogelio and Zenaida became members of CIPAA to help with the
cultural center project. In 1991, Rogelio and Zenaida applied
for and obtained positions with the CIPAA Casino; each of them
worked for the CIPAA Casino during each of the years in issue.
After receiving extensive training from the CIPAA Casino’s
management, Rogelio became a low-stakes blackjack dealer; Zenaida
became a roulette dealer. Rogelio began working for the CIPAA
Casino on or about March 30, 1991; Zenaida began on or about
November 23, 1991. Rogelio and Zenaida maintained their full-
time positions with Validity Corporation and First American Bank,
respectively, in addition to the positions they held at the CIPAA
Casino.
Each petitioner worked for the CIPAA Casino most Saturdays
and most Tuesdays. For 1991 and 1992, each petitioner typically
worked for the CIPAA Casino 14 hours on Saturdays. Rogelio
typically worked for the CIPAA Casino 11 hours on Tuesdays;
Zenaida typically 6 hours on Tuesdays. (The record does not
include time sheets or equivalent information for 1993.)
Rogelio became a pit boss at some point. (See infra note
3). Rogelio became treasurer of the CIPAA Casino in 1994.
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