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To create the appearance of compliance with Maryland law,
the CIPAA Casino’s management and staff, including dealers, (1)
characterized all remuneration they received from the CIPAA
Casino as tips, the receipt of which was believed to be legal,
and (2) referred to themselves as volunteers rather than
employees. The CIPAA Casino’s management told the staff that
amounts received from the CIPAA Casino were not to be reported to
the Internal Revenue Service as wages.
CIPAA Casino employees also received tip income through the
CIPAA Casino. On each gaming table at the casino premises were
two boxes: One for cash that bettors exchanged for chips at the
table, and one for chips and cash that the bettors gave to the
dealers as tips. The latter box is sometimes hereinafter
referred to as a tip box. Each hour a “runner” collected both
boxes. The moneys in the tip boxes were then commingled and
distributed to the pit bosses and dealers in proportion to their
hourly compensation; i.e., hourly rate times amount of time
worked. The CIPAA Casino distributed tip income about every 3
weeks.
Some pit bosses and dealers also received tips directly from
casino patrons. These tips were not placed into the table’s tip
box and were not divided in the manner described above. Rather,
the recipient of the tip simply kept it for personal use. The
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Last modified: May 25, 2011