- 15 -
Also, there is no currency transaction report in evidence
with respect to the Fortune Bank withdrawal. Currency
transaction reports are required to be prepared by banking
institutions when customers conduct single cash transactions
(deposits, withdrawals, exchanges of currency, or other payments
or transfers) in amounts of $10,000 or greater. 31 U.S.C. sec.
5313 (1994). We infer from petitioner's failure to offer a
currency transaction report for the alleged withdrawal of $10,000
cash that no such withdrawal of cash occurred.
Petitioner has failed to prove nontaxable sources for either
the Fortune Bank deposit or the NationsBank purchase.
6. Conclusion
Because petitioner has failed to prove nontaxable sources
for the cash transactions, respondent’s determination of
deficiencies with respect to his adjustments made with respect to
the cash transactions is sustained.
B. Tax on Self-Employment Income
Section 1401 imposes a two-part tax on the self-employment
income of every individual. An individual’s self-employment
income depends on his “net earnings from self-employment”. See
sec. 1402(b). In relevant part, the term “net earnings from
self-employment” means the gross income derived by an individual
from any trade or business carried on by the individual less
allowable deductions attributable to the trade or business. Sec.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011