South Community Association - Page 18

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          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 guards             

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