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During the years of operation of the casino, each enrolled
member of the Prairie Island Indian Community who lived on the
reservation received per capita distributions of a portion of the
casino's earnings for that year.2 In other words, a portion of
the casino's earnings each year was divided equally among, and
distributed to, each man, woman, and child who was an enrolled
member of the Prairie Island Indian Community who lived on the
tribe's reservation.3 During the year in question, 1992,
petitioner's per capita distribution from the casino operations
was $43,380.4 Each enrolled member of the Prairie Island Indian
Community who lived on the reservation received a $43,380
distribution from the casino operations in 1992. The payment of
the $43,380 per capita distribution to petitioner was reported to
respondent by the tribal council on Form 1099-DIV.
2
The Court surmises from the record that, originally, these
distributions were paid on a quarterly basis, but eventually the
payments were made on monthly basis.
3
Through 1994, each member of the tribe who lived on the
reservation, including children of all ages, received an equal
distribution of the earnings. For 1995 and subsequent years, the
apportionment was altered so that the children (those under the
age of 18) received only 15 percent of the amount of the
distributions received by the adults.
4
Petitioner testified that he received the following per
capita distributions from casino operations for years prior and
subsequent to the year at issue: (1) for 1990--$200, (2) for
1991--$19,000, (3) for 1993--$45,000, (4) for 1994--between
$70,000 and $80,000, and (5) for 1996--between $90,000 and
$100,000. Petitioner did not file a Federal income tax return
for any of these years.
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