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were physically present at the bingo games and at the locations
of the instant pull-tab ticket sales, and they were an integral
part of those activities. While petitioner asks this Court to
view the role of the security guards narrowly so as not to
consider them as working in the gaming operation absent their
acting in the setting of a robbery or an attempted robbery, we
decline to do so. The role of the security guards as we see it
was to prevent a robbery from being attempted in the first place,
primarily by virtue of their physical presence at the sites of
the bingo games and the instant pull-tab ticket sales. We
consider the security guards to be part of the workforce of the
gaming operation, cf. Waco Lodge No. 166, Benevolent & Protective
Order of Elks v. Commissioner, 696 F.2d 372 (5th Cir. 1983)
(concluding that a bartender’s services on bingo night were
connected with the carrying on of the bingo games although the
bar was down the hall from the games), affg. T.C. Memo. 1981-546,
and conclude that the security guards worked in the gaming
operation for purposes of the “substantially all” test.
Accordingly, on the basis of our review of the record before
us, we find that many (if not all) of the workers in the gaming
operation were compensated for their work. We do not find that
any of the workers in the gaming operation were uncompensated
within the meaning of section 513(a)(1). The gaming operation
was petitioner’s principal activity and was conducted by
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