Joseph Campbell v. Commissioner IR

Joseph Baldwin Campbell, a member of the Prarie Island Indian Community (the tribe), leased land from the tribe for farming until the tribe reclaimed the land to expand its gambling operations from bingo (class II gaming) to a casino (class III gaming) in 1992. As an enrolled member of the tribe, Campbell receives per capita distributions from the tribe’s gambling profits. In 1991, 1992, 1993, and 1994, per capita distributions were made to Campbell. The tribe reported the per capita distributions to the Internal Revenue Service (IRS) on Forms 1099-DIV, but did not withhold federal taxes.…