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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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