We know the rules against "lotteries". In reading the reg. we believe we'd be ok doing a silent auction where bids are anonymously submitted and at a stated time all bids are opened with the highest receiving the prize. Anyone disagree?

Also, can someone explain section (2)(C)to us? We can't figure out what it really means. Thanks.

(2) The term "lottery" includes any arrangement whereby three or more persons (the "participants") advance money or credit to another in exchange for the possibility or expectation that one or more but not all of the participants (the "winners") will receive by reason of their advances more than the amounts they have advanced, the identity of the winners being determined by any means which includes--

(A) a random selection;

(B) a game, race, or contest; or

(C) any record or tabulation of the result of one or more events in which any participant has no interest except for its bearing upon the possibility that he may become a winner.