United States v. Francis Ditommaso A/K/A "Checco", Rudolfo Risatti, A/K/A "Rudy", Sheila Silvetti, Victoriano Molina-Chacon
Court of Appeals for the Second Circuit
1Opinion of the Court
DAVIS, Circuit Judge:
BACKGROUND 1
In late 1981, Antonio Turano, a United States resident, Gaetano Giuffrida, a resident of Italy, and Victoriano Molina-Chacon, a resident of Spain, formed a partnership, ostensibly for the purpose of operating a multinational shoe business. The trio employed Rudolfo Risatti as chief shoe salesman with responsibility for the collection of accounts receivable. From the outset, the joint enterprise suffered from serious financial difficulties and Risatti’s claimed adjusted gross income from shoe sales in 1982 was approximately $2000. Although the sale of footwear…
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