Ianniello v. Comm'r
United States Tax Court
Petitioner husbands (Ps) were convicted of mail fraud, Federal income tax evasion, and violations of the Racketeer Influenced and Corrupt Organization Act (RICO), 18 U.S.C. secs. 1961-1968 (1988). Ps were each sentenced to prison, fined, and ordered to forfeit $ 666,667 as his share of the restaurant receipts they skimmed in violation of RICO during 1979 through 1982. Ps satisfied the judgments of forfeiture in 1989 and 1990. R determined Federal income tax deficiencies and…
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Petitioner husbands (Ps) were convicted of mail fraud, Federal income tax evasion, and violations of the Racketeer Influenced and Corrupt Organization Act (RICO), 18 U.S.C. secs. 1961-1968 (1988). Ps were each sentenced to prison, fined, and ordered to forfeit $ 666,667 as his share of the restaurant receipts they skimmed in violation of RICO during 1979 through 1982. Ps satisfied the judgments of forfeiture in 1989 and 1990. R determined Federal income tax deficiencies and fraud additions to tax under sec. 6653(b), I.R.C., for 1981 and 1982 arising from Ps' failure to report the skimmed…
1Opinion of the Court
OPINION
BEGHE, Judge:
Respondent determined deficiencies in Federal income tax and additions to tax as follows:
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1Miriam Cohen and Beatrice Ianniello each filed separate petitions, not among the cases consolidated in this proceeding, for the taxable year 1981. We filed our opinions in these cases on Aug. 22, 1991. Ianniello v. Commissioner, T.C. Memo. 1991-415; Cohen v. Commissioner, T.C. Memo. 1991-413.
Taxable Additions to tax
year Petitioners Deficiency sec. 6659
1982 Matthew & $76,817 $23,045.10
Beatrice Ianniello
Unless otherwise noted, all section references are to the Internal…
2Cases cited35 opinions
- Blockburger v. United StatesSupreme Court of the United States · 1931
- Russello v. United StatesSupreme Court of the United States · 1983
- United States v. HalperSupreme Court of the United States · 1989
- Grady v. CorbinSupreme Court of the United States · 1990
- Helvering v. MitchellSupreme Court of the United States · 1938
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