Following is correspondence from the Mississippi Gaming Commission concerning the WIN CARDS® Program:
MISSISSIPPI GAMING COMMISSION
Post Office Box 23577
Jackson, Mississippi 39225-3577
(601) 351-2800
March 29, 2002
Mr. Ted Gottlieb, President
Gaming International, Inc.
P.O. Box 4977
Lake Tahoe, Nevada 89449
Dear Mr. Gottlieb:
In response to your letter, dated October 9, 2001, inquiring as to the possibility for the use of special, free-play, non-negotiable casino chips to be included in the “WIN” Card package, The Mississippi Gaming Commission has made the following determination:
In your proposal, the customer would receive, with the purchase of the “WIN” Card package, $15.00 in special free-play, non-negotiable chips (Fifteen (15) one dollar valued chip) and a set of WIN CARDS for the purchase price of $10.00. This example reflects the “WIN” Card package being sold to the patron for more than cost. The Mississippi Gaming Commission concludes that the $5.00 net received ($10.00) sales price - $5.00 cost) is revenue that should be included in drop. Assuming that the $15.00 in promotional chips consists of fifteen $1.00 non-negotiable chips, 1/3 of the wagering value of each $1.00 non-negotiable chip dropped should be included in gaming revenue.
The guidance provided in this letter is strictly associated with the use of special, free-play, non-negotiable casino chips as a part of the “WIN” Card promotion, and should not extend to other promotions with differing items as part of the promotion. The guidance provided is in accordance with Mississippi Gaming Commission Regulation VII “Internal Controls For Gaming Establishments,” Section G “Gross Revenue Computation.” Prior to implementing the “WIN” Card promotion utilizing the special, free-play, non-negotiable casino chips, each Mississippi gaming establishment must submit internal controls to the Mississippi Gaming Commission for approval. The internal controls must detail the accounting treatment and record keeping requirements for this promotion.
Please be advised that the Mississippi Gaming Commission must approve the use of any free-play, non-negotiable casino chips prior to implementation. All chips utilized must be designed, manufactured, and used in accordance with Mississippi Gaming Commission Regulation III “Operations,” Section E “Chips and Tokens.”
The Mississippi State Tax Commission should be contacted to render a determination on the requirement of sales tax for this promotional item. Also, it is the responsibility of Gaming International, Inc. to maintain compliance with all regulatory requirements from other governing agencies related to the sale of the “WIN” Card package.
Sincerely,
Brenda Redfern, C.P.A., I.D.
Deputy Executive Director
Mississippi Gaming Commission
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