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petitioner reportedly paid Clausing compensation of $4,800,
$27,600, $32,428, and $41,627, respectively. As to the gaming
operation, Clausing negotiated the bingo supply contracts, ran
the bingo games, handed out tickets at the bingo games, collected
the proceeds from petitioner’s sales of bingo cards and instant
pull-tab tickets, deposited most of petitioner’s daily proceeds
in the bank, prepared daily sheets, and managed petitioner’s
inventory (e.g., of instant pull-tab tickets). Clausing also
each day visited the sites where petitioner sold its instant
pull-tab tickets and, when there, counted money and prepared
daily sheets. As to petitioner’s activities other than the
gaming operation (nongaming operation), Clausing ran petitioner’s
monthly board meetings, made annual decisions about grants, and
wrote checks to petitioner’s grant recipients. The amount of
time that Clausing spent on petitioner’s nongaming operation was
substantially less than the amount of time that Clausing spent on
the gaming operation.
Carroll was petitioner’s vice president in 1992 through 1995
and an administrator of its gaming operation in 1994 and 1995.
Carroll reportedly was not paid by petitioner in 1992 and 1993.
Petitioner reportedly paid Carroll $18,928 and $23,427 in 1994
and 1995, respectively. Carroll worked for petitioner an average
of 10 hours per week in 1994 and an average of 40 hours per week
in 1995. As part of his work for petitioner, Carroll sometimes
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