A taxpayer who already had a criminal prosecution for tax evasion was slapped with additional tax of $116,828 and penalties of $87,620 for unreported income from two nail salon businesses. The taxpayer initially argued the sums deposited in various bank accounts were not taxable transactions because the funds represented gifts or loans from family members and friends. He also structured his deposits so he did not have to sign the declaration required when a deposit exceeds the daily limit of $10,000. After the taxpayer made deposits of $5,000 each at six different Union Bank branches over three days, the bank filed a Suspicious Activity Report. (Le v. Comm., TCM 2020-27)
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