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Additions to Tax
Year Deficiency Sec. 6653(b) Sec. 6661
1983 $168,488 $84,244 $42,122
1984 64,130 32,065 16,033
1985 54,404 27,202 13,601
1986 122,711 92,033 30,678
1988 51,165 38,374 12,791
In their petition, filed on July 10, 1996, Ernest and Ann
Infelise challenged respondent's determinations. After
concessions, the only remaining issue is whether Mrs. Infelise is
entitled, pursuant to section 6013(e), to innocent spouse relief.
All section references are to the Internal Revenue Code in effect
for the years in issue.
FINDINGS OF FACT
Ann Infelise resided in Hollywood, Florida, when the
petition was filed. On March 20, 1981, she had married Ernest
Infelise, a reputed member of the Chicago organized crime
community. Before and during their marriage, Mr. Infelise
operated an extensive illegal gambling business that included
sports bookmaking and a variety of card games. Shortly before
their marriage, Mrs. Infelise attended a "going away party" for
Mr. Infelise's partner, Mr. William Jahoda, who had been
convicted of Federal income tax fraud and sentenced to 2 years in
prison. At the party, and in Mrs. Infelise's presence, Mr.
Infelise and Mr. Jahoda discussed how the gambling activities
would be reorganized during Mr. Jahoda's incarceration.
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Last modified: May 25, 2011