conducted his criminal activities in his home. He held business meetings there, he collected and stored hundreds of thousands of dollars there, and he maintained his business records there. It is undisputed that petitioner greeted Mr. DiMichele's business associates when they came to the home for meetings with Mr. DiMichele. There is also persuasive evidence in the form of testimony by one of Mr. DiMichele's business associates, Mr. Michael Madgin, that at least one meeting took place in petitioner's presence during which Mr. DiMichele, Mr. Madgin, and another person counted money and discussed illegal drug activities. We also credit Mr. Madgin's testimony that he delivered to petitioner a payment of cash in the amount of $50,000 to $100,000 for Mr. DiMichele. Furthermore, there is ample evidence that petitioner was aware of the fruits of her husband's illegal drug activities and, hence, knew or should have known of the substantial understatements of tax attributable to unreported income in both 1985 and 1986. The investigation conducted by the DEA agents in 1987 and their searches of petitioners' home and safe deposit boxes revealed that thePage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011