Ernest R. Infelise and Ann Infelise - Page 2

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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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