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On July 19, 1994, Mr. Strong obtained two cashier’s checks
issued by Norwest Bank each in the amount of $8,500. The first
made payable to Mr. Strong shows the payor was his brother, Sean
Strong and was deposited to account No. 893315300 on August 16,
1994. The second was made payable to Mr. Strong, and Jack
Thompson, the payor, is unidentified. It was deposited into
account No. 893315300 on August 10, 1994.
Before 1990, Mr. Strong was aware of the title 31
requirements that currency transactions in excess of $10,000 be
reported to the Government.
SCC’s Activity
During the years at issue, SCC entered into vacant land
purchase agreements and acquired real property in its name. Mr.
Strong signed the purchase agreements as president of SCC. As
part of the sales process, SCC entered into new construction
purchase agreements with buyers. SCC also applied for building
permits, which Mr. Strong signed as president of SCC. In
addition, SCC entered into a builder’s security agreement and
applied for a home buyer’s warranty on some of the 22 house
sales. SCC was identified as the seller of the property on the
settlement statements or closing statements prepared for the real
estate property closings for the 22 house sales. Mr. Strong
executed those statements as president of SCC. For the purpose
of passing title to real property, Mr. Strong executed, as
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