Anthony and Linda Walters - Page 6

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          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).                                      




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