South Community Association - Page 16

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          respondent’s three witnesses seek revenge against petitioner                
          because their services in the gaming operation were discontinued.           
          We find this attempt unavailing.  Given that none of respondent’s           
          three witnesses reported her receipt of the $65 cash payments as            
          income, we do not believe that they simply out of revenge                   
          testified against their self-interests by admitting clearly and             
          under oath that they received the $65 payments and knowingly did            
          not report those payments as income.                                        
               In addition to its witnesses, petitioner relies upon                   
          approximately 29 affidavits contained in the administrative                 
          record.  These affidavits, which were mostly signed in bulk in              
          June or September of 1997 and were submitted to respondent during           
          the audit, were from various workers of petitioner and stated               
          that the affiant was not paid for his or her services in the                
          gaming operation.  We are unpersuaded by these affidavits, and we           
          give them no weight.  The affiants included 12 workers of                   
          petitioner who did not work for petitioner during the relevant              
          years and 4 of petitioner’s officers (including Clausing,                   
          Carroll, and Whitaker).  Many of the affiants did not testify at            
          trial so as to be subject to our determination of their                     
          credibility or to questioning as to the circumstances under which           
          they signed or otherwise acquiesced in the statements contained             
          in the affidavits.  As to the affidavits, most of them were                 
          written pro forma on petitioner’s letterhead and were prepared by           

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