Francisco A. Murillo - Page 6

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          traceable to such property" is subject to forfeiture to the                 
          United States.  18 U.S.C. sec. 981(a)(1)(A).  The title 31                  
          sections establish the Federal Government's policy against                  
          structuring.  See Stephens v. Commissioner, 905 F.2d at 670.  To            
          allow petitioner a deduction for losses arising out of illegal              
          activities would undermine public policy by permitting a portion            
          of the forfeiture to be borne by the Government, thus taking the            
          "sting" out of the forfeiture.  See Tank Truck Rentals, Inc. v.             
          Commissioner, 356 U.S. 30, 35 (1958); Wood v. United States,                
          supra at 422; Holt v. Commissioner, 69 T.C. 75, 81 (1977), affd.            
          611 F.2d 1160 (5th Cir. 1980); Farris v. Commissioner, T.C. Memo.           
          1985-346, affd. without published opinion 823 F.2d 1552 (9th Cir.           
          1987).  Petitioner seeks to draw a line between his situation and           
          the cases denying deductions for forfeitures on the ground that             
          such cases involved drug dealers whose activities involve much              
          more serious violations of law than his structuring of bank                 
          deposits.  We think this distinction is without merit.  The                 
          Congress, by its enactment of the antistructuring statutory                 
          provisions, established a declared public policy.  Taking into              
          account the "presumption against congressional intent to                    
          encourage violation of declared public policy", Tank Truck                  
          Rentals, Inc. v. Commissioner, supra at 35, and that the                    
          antistructuring provisions constituted subtitle H of the Anti-              
          Drug Abuse Act of 1986, Pub. L. 99-570, 100 Stat. 3207, 3207-22,            

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