In a memo prepared for tax authorities while the investigation was continuing, Vittorio Marzotto wrote that the sale to Permira was an "unhoped for and unexpected" outcome.

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Prosecutors say they found a memo showing that in 2008, the Marzotto family members sought the advice of a tax lawyer, who advised them to file an Italian tax return on the sale, which they didn't do.

WSJ: Italy Scours Deals Abroad for Elusive Tax Revenue