John DiFronzo - Page 6

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          Gilmore as 'expenses paid or incurred * * * in carrying on any              
          trade or business' within the meaning of section 162(a)."  Id. at           
          689.                                                                        
               The criminal convictions in this case provide proof of                 
          petitioner's involvement in an illegal trade or business.  The              
          indictment alleges that                                                     
                    6.  The Chicago organized crime family obtained                   
               income through the pursuit of a variety of illegal                     
               activities, including but not limited to bookmaking,                   
               loansharking, extortion, illegal gambling, trafficking                 
               in stolen property, and fraud, and would travel in                     
               interstate commerce in furtherance of those activities.                
                                                                                     
          It also alleges that petitioner was a "crew chief", or a mid-               
          level leader in the Chicago organized crime family.  The                    
          indictment chronicles petitioner's involvement in one particular            
          money-making scheme.  Specifically, petitioner and his                      
          confederates planned to invest money in a gambling operation                
          without disclosing to the Rincon Indians that the money came from           
          the Chicago organized crime family.  They planned to structure              
          the gambling operation in such a way that the crime family would            
          maximize its profits at the Indians' expense.  They also planned            
          to skim profits and use the operation to launder funds from other           
          illegal activities of the crime family.                                     
               The criminal charges against petitioner originated from his            
          business activities as a member of the Chicago organized crime              
          family.  His legal fees, incurred in defense of those charges,              
          are deductible under section 162(a).                                        




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