Fredric Arlan Dubray - Page 3

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               During the years at issue, petitioner was employed by the              
          corporation.  The corporation was owned and operated by the                 
          Cheyenne River Sioux for purposes of restoring buffalo to tribal            
          lands.  The corporation raised buffalo on tribal land, and the              
          buffalo were used for various purposes, including slaughter for             
          tribal and public consumption and sale, and for use in tribal               
          ceremonial events.  Petitioner’s position with the corporation              
          was director of the buffalo restoration project.                            
               During the years at issue, the corporation paid petitioner             
          wages for his services as director and reported those wages to              
          respondent and petitioner via Forms W-2, Wage and Tax Statement.            
          The corporation deducted withholding tax, FICA tax, and medicare            
          from petitioner’s wages, and those deductions were also reported            
          on the Forms W-2.  The wages paid by the corporation were                   
          $33,860, $37,105, and $37,600 for 1997, 1998, and 1999,                     
               The source of the wages paid petitioner by the corporation             
          is not clearly described in the record, but the wages are not               
          exclusively from revenue related to the buffalo restoration                 
               Petitioner also received various other items of income he              
          concedes are taxable to him during the years at issue and are no            
          longer in dispute.                                                          

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