- 18 - exempt organization did not pay the workers directly); cf. Piety, Inc. v. Commissioner, 82 T.C. 193, 194 (1984) (finding that workers who conducted bingo games in a building rented by the organization were “compensated” when the organization’s rental payments included payment for “all labor for the supervision and handling of each bingo occasion upon the premises”). Petitioner also argues that the security guards were not petitioner’s workers in that petitioner paid the security agency to safeguard petitioner against an attempted theft or robbery and the guards did not actually work in carrying on petitioner’s gaming operation. In this regard, petitioner asserts, the security guards were not an attraction important to the success of the gaming operation, the security guards provided little labor in the absence of a theft or robbery, and the gaming participants received no direct products or services from the security guards. In addition, petitioner asserts, the guards never called bingo numbers, never sold bingo cards or instant pull-tab tickets, and never assisted in the actual administration of the gaming operation. We find petitioner’s argument unpersuasive. If the security guards had not been present at the bingo games, petitioner would have been precluded from conducting these games by virtue of the State law requirement that security guards be present at bingo games. Moreover, irrespective of that law, the security guardsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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