Beatrice DiPierro - Page 15




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               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.           





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