Carl Dimichele and Eileen Dimichele - Page 20

             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 the               

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