-26-
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,
Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 NextLast modified: May 25, 2011