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31 U.S.C. sections 5322(a) and 5324(3) (structuring a transaction
to avoid a cash transaction report).
B. Dogwood Acres, Inc.
Dogwood Acres, Inc. (Dogwood Acres), was a closely held
Florida corporation and a subchapter C corporation. Petitioner
and his brother each owned 49 percent of its stock. Mrs. Barrow
and petitioner's mother and father owned the other 2 percent.
Dogwood Acres owned a family farm in northern Florida.
Dogwood Acres' taxable years ended on March 31. Dogwood Acres
did not file an income tax return or report any income or loss
for its taxable year ending on March 31, 1984.
C. The Holiday Isle Property Transaction
George Dana Harris (Harris) was one of petitioner's clients
during the years in issue. Harris bought, sold, and developed
real estate through fictitious business names including Saudi
Corp. and Fujimo Corp. On September 21, 1983, Harris was
convicted of tax evasion under section 7201 and willful failure
to file under section 7203.
In the 1970's, petitioner owned an interest in a parcel of
real property in northern Florida known as Holiday Isle. He lost
it to Southeast First National Bank of Miami because of a
foreclosure suit in 1979. In 1981, Harris, acting as Saudi
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