- 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
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