- 6 - codified at 31 U.S.C. sec. 5313(a) (1988), and its supporting regulation2 requiring that financial institutions report currency transactions in excess of $10,000. Petitioner explained that many of the cashier's checks were slightly under the $10,000 threshold simply because the institution from which the cashier's checks were purchased assessed a $5 fee for the purchase of cashier's checks in amounts equal to or greater than $10,000. As part of their partnership agreement, petitioner and Carlton had orally agreed that their compensation with regard to the services provided to Fruitland was to be equal. Nevertheless, neither petitioner nor Carlton had devised a method for ensuring that this agreement would be carried out with any degree of precision. Their agreement was simply based on trust. Carlton received a salary, payable biweekly, in exchange for the services he provided to Fruitland. Petitioner, on the other hand, did not receive a salary. Instead, in exchange for the services he provided to Fruitland, petitioner was authorized to draw checks against the partnership's checking account for personal purposes. During the years at issue, petitioner wrote checks against the partnership's account in order to pay personal living expenses in the following amounts: Year Amount 1987 $30,691 1988 44,969 231 C.F.R. sec. 103.22(a) (1994).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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