Variety Club Tent No. 6 Charities, Inc. - Page 26

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          member of petitioner’s board of trustees.  The parties have                 
          stipulated that petitioner’s president during each of the years             
          in issue delegated to Zeve and Popovic the authority and duties             
          incident to the conduct of the bingo games, and that petitioner’s           
          procedures for the conduct of the bingo games and for the                   
          handling of the proceeds thereof vested ultimate authority and              
          responsibility with Zeve.  As shown supra table 1, bingo                    
          accounted for more than 90 percent of petitioner’s gross revenues           
          and about 60 percent of petitioner’s net income during the years            
          in issue.                                                                   
               Clearly, during the years in issue Zeve had a significant              
          formal voice in petitioner’s activities generally and had                   
          substantial formal and practical control over most of                       
          petitioner’s income.                                                        
               We conclude, and we have found, that Zeve was an insider               
          with respect to petitioner during each of the years in issue.               
               (2) Popovic                                                            
               Popovic operated all of petitioner’s bingo games during the            
          years in issue; he did so at Zeve’s request.  Petitioner’s                  
          president during each of these years delegated to Zeve and                  
          Popovic the authority and duties incident to the bingo games.               
          Although Popovic was a member of petitioner, he never was an                
          officer or member of the board of trustees.  Popovic did not have           
          any formal voice in petitioner’s activities generally.  However,            
          in his stipulated role as operator of petitioner’s bingo games,             




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