Joseph B. Campbell - Page 6

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          of the ownership and operation of the casino.  Campbell I was               
          tried before Special Trial Judge D. Irvin Couvillion on October             
          4, 1996, in St. Paul, Minnesota.  The Court issued an opinion in            
          Campbell I on November 6, 1997, in which it held that the per               
          capita distributions were taxable as ordinary income rather than            
          exempt farm income as asserted by petitioner.  See Campbell v.              
          Commissioner, T.C. Memo. 1997-502.  On January 8, 1999, the Court           
          of Appeals for the Eighth Circuit affirmed the Tax Court on this            
          issue and remanded the case on another issue irrelevant to this             
          case.  See Campbell v. Commissioner, 164 F.3d 1140 (8th Cir.                
          1999).  The U.S. Supreme Court denied a petition for writ of                
          certiorari.  See Campbell v. Commissioner, 526 U.S. 1117 (1999).            
          Gaming Revenue Allocation Ordinance                                         
               On or about October 19, 1994, the tribe passed a resolution            
          to amend its constitutional powers and adopted a Gaming Revenue             
          Allocation Ordinance (the ordinance) which regulates the                    
          distribution of tribal profits to tribe members.  The ordinance             
          was passed and adopted in accordance with the requirements of the           
          Indian Gaming Regulatory Act (IGRA), Pub. L. 100-497, secs. 1-22,           
          102 Stat. 2467 (1988), current version at 25 U.S.C. secs. 2701-             
          2721 (Supp. 2000).  The ordinance stated, in part:                          
               The Tribal Council shall insure that notification of                   
               the application of federal tax laws to tribal per                      
               capita payments be made when such payments are made.                   
               The Tribal Administration shall also implement a                       
               procedure by which qualified enrolled members who                      
               receive per capita payments can have applicable taxes                  

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