South Community Association - Page 6

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          activities were deposited.  Petitioner generally paid each of its           
          nonofficer/nonsecurity guard workers $65 in cash a day for his or           
          her work in the gaming operation (exclusive of tips or Christmas            
          bonuses).  Petitioner did not report any of these payments either           
          to the recipient (e.g., through a Form W-2, Wage and Tax                    
          Statement) or to respondent.  In addition to working for                    
          petitioner in the gaming operation, many of the nonofficer/                 
          nonsecurity guard workers also worked fulltime for employers                
          other than petitioner.  At least one of the nonofficer/                     
          nonsecurity guard workers traveled more than 20 miles to work in            
          the gaming operation.                                                       
               Ohio law requires that a security guard be present during              
          the bingo games, and petitioner paid a security agency to furnish           
          a security guard to work at the bingo games while the games were            
          conducted.  Petitioner also paid the security agency to furnish a           
          security guard to work with petitioner’s instant pull-tab ticket            
          workers when, and on the sites where, the instant pull-tab                  
          tickets were sold.  For the services of these security guards,              
          petitioner paid the security agency $7,776, $12,936, $9,908, and            
          $11,643 during 1992 through 1995, respectively.                             
               Clausing was petitioner’s president and full-time                      
          administrator from 1992 through 1995.  He worked for petitioner             
          an average of 30 hours per week in 1992 and an average of 35                
          hours per week in 1993 through 1995.  During 1992 through 1995,             

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