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Petitioner resided in Welch, Minnesota, when the petition
was filed. As of the date the statutory notice of deficiency was
mailed to petitioner, he had not filed Federal income tax returns
or made any estimated tax payments for 1990, 1991, 1993, and
1994.
Petitioner is an enrolled member of the tribe and resided on
its reservation at all relevant times. Petitioner started
farming on the reservation in or around 1979. Petitioner raised
corn and soybeans on approximately 270 acres of reservation land
which he leased from the tribe until about 1992. In 1992, the
tribe reclaimed the land to expand its gambling operations.
The tribe approved its constitution and bylaws on June 20,
1936, and ratified its corporate charter on July 23, 1937.
Per Capita Distributions
The tribe owns and operates a gambling casino complex called
Treasure Island Casino & Bingo (the casino) on its reservation.
The tribe initially conducted class II gaming at the casino. On
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