- 6 - Petitioner entered into a promotional contract with R.J. Reynolds Tobacco Co. (R.J. Reynolds) having an effective date of January 1, 1996, and no specific term or ending date. Pursuant to the contract, petitioner was to receive quarterly promotional payments of $13,164 upon meeting certain sales volume requirements set by R.J. Reynolds. During 1997, petitioner negotiated a $13,164 check issued by R.J. Reynolds to purchase a cashier’s check. The check was dated October 27, 1997, and was for the same amount as called for in the promotional contract. Based on petitioner’s records, respondent determined that petitioner’s rack and promotional income totaled $69,915 ($63,940 + $5,452 + $523). Respondent also determined that petitioner underreported rack and promotional income by $53,179 ($69,915 less $16,736 reported). During the examination, Mercantile National Bank (Mercantile), informed respondent that during 1997, petitioner acquired 31 cashier’s checks totaling $809,734. Petitioner exchanged cash and negotiated third party checks he received from business-related and personal sources for the cashier’s checks. Petitioner, by using third party checks and cash less than $10,000 in amount to purchase the cashier’s checks, tried to avoid the reporting of cash transactions exceeding $10,000 to the Internal Revenue Service. Petitioner did not inform hisPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011