- 2 - fraud, are, to the extent substantiated, deductible as ordinary and necessary business expenses under section 162(a).1 This case was submitted on the basis of a stipulation of facts. Petitioner, John DiFronzo, resided in River Grove, Illinois, when the petition in this case was filed. On January 9, 1992, petitioner was indicted by the Grand Jury in the United States District Court for the Southern District of California, Criminal Case No. 92-0026 E. He was charged with a variety of federal offenses, including mail and wire fraud, and conspiracy to commit mail and wire fraud. The indictment generally alleged that petitioner and other members of the Chicago organized crime family planned to contract with the Rincon Band of Mission Indians to control gambling operations on the Rincon Indian Reservation. The defendants meant to conceal that the money they invested came from the Chicago organized crime family. The defendants intended to structure the operation so as to maximize their profits. They intended to skim profits from the operation without the knowledge of the Rincon Indians. They also intended to use the operation to launder the proceeds from other illegal enterprises of the Chicago organized crime family. 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011