- 27 - income, but instead espoused inconsistent and implausible explanations. The Court concludes that the $54,000 deposited by petitioners into their Leadenhall bank account was unreported income. Accordingly, the Court sustains respondent’s determination on this issue. B. Money and Finance Regulations Regulations prescribe that transactions involving the transfer of more than $10,000 in monetary instruments at one time from the United States to a place outside of the United States, or vice versa, must be reported to the Secretary of the Treasury by the individual involved. See 31 U.S.C. sec. 5316 (2000); 31 C.F.R. sec. 103.23 and 103.27 (2000). “Monetary instruments” includes all negotiable instruments, such as checks. 31 C.F.R. 103.11(u) (2000). Violation of the reporting requirements applicable to the exportation or importation of monetary instruments can result in criminal penalties consisting of fines, imprisonment, or both. See 31 U.S.C. sec. 5322 (2000). In response to questioning regarding the avoidance of such reporting requirements, Mr. Wright could not explain why he would issue six $9,000 checks (all drawn on the same Sun Trust bank account) over a period of 3 consecutive days, all to be deposited on the same day in the Bahamas, instead of one check for $54,000. The Court concludes that Mr. Wright structured petitioners’ deposit transaction so as to avoid the exportation of monetaryPage: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
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