Alfred L. and Renee E. Fields - Page 4




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          The 4 Leaf Corporation                                                       
               The 4 Leaf Corporation (4 Leaf Corp.), a Virginia corporation,          
          was incorporated on April 21, 1992.  At all relevant times, 4 Leaf           
          Corp. had its principal place of business in Hampton, Virginia               
          (City of Hampton). During the years under consideration, Alfred              
          Fields (Mr. Fields), Mr. Bullock, Leroy Sharpe (Mr. Sharpe), and             
          Mr. Peacock each owned 25 percent of 4 Leaf Corp.'s outstanding              
          stock.                                                                       
               On October 6, 1992, 4 Leaf Corp. leased a building located in           
          Hampton, Virginia, which became known as the Buckroe Plaza Bingo             
          Hall (Buckroe).  It was originally intended that the building would          
          be used for concerts, dances, bingo, and conferences. However,               
          after the City of Hampton prohibited 4 Leaf Corp. from sponsoring            
          a dance at the building, Buckroe was used exclusively as a bingo             
          hall.                                                                        
          Bingo Operations at Buckroe                                                  
               Under Virginia law (1) only “qualified organizations” (i.e.,            
          charitable and fraternal organizations) may operate bingo games,             
          and (2) the workers at the games must be members of those                    
          charitable and fraternal organizations, working as volunteers.  See          
          Va. Code Ann. secs. 18.2-3450.1-4, 18.2-340.9 (Michie 1993).                 
               During 1993, the bingo games at Buckroe were sponsored by two           
          charitable organizations: The Association for the Restoration of             
          Historic Cemeteries (the cemeteries restoration association) and             





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