South Community Association - Page 19

                                       - 19 -                                         
          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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