§5313 — Withdrawal of distilled spirits from customs custody free of tax for use of the United States

After concessions, we must decide: (1) Whether petitioner is liable for the accumulated earnings tax imposed by section 5313 for fiscal years 1987, 1988, and 1989.

Chernomordikov paid suppliers indirectly as well. For example, he transferred a total of $825,000 from ONY Sales’ bank accounts to title company escrow accounts to fund the purchase of houses for Messrs. Rueda and Orozco. Respondent conceded that these transfers did not constitute income to Mr. Chernomordikov. Although he did not own an

5313 (1994); 31 C.F.R. sec. 103.22 (1998). - 27 - [*27] On the basis of the record the Court concludes that petitioner has failed to meet his burden to prove that respondent’s method of income reconstruction is unfair or inaccurate under the specific deposits method for any of the relevant amounts deposited into petitioner’s bank accounts. Th

5313(a) (1994) (requiring that financial institutions report currency transactions in excess of$10,000); 31 C.F.R. sec. 103.22 (1995) (same). He also failed to cooperate with tax authorities when he refused his initial interview and refused to turn over the list of"donors" that he purported to have. Additionally, petitioner's testimony often l

5313(a), in violation of 31 U.S.C. secs. 5322(b) and 5324(a)(3) and 18 U.S.C. sec. 2. In September 1992, Steele and the U.S. Attorney for the Southern District of New York agreed that Steele would plead guilty to this information and that the information would be transferred to the District of New Jersey (the resulting case filed as Crim. No.

5313 and 31 C.F.R. sec. 103.22 (2000), as to any nonexempt customer who in a single day transacted business at the Bank involving cash totaling more than $10,000 and (2) an STR as to any other nonexempt customer who the Bank perceived was engaging in a “suspicious activity”. The Bank generally considered exempt customers to be those retail bus

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 nonta

5313(a) (1994); 31 C.F.R. sec. 103.22 (1995). - 30 - In addition to the items specifically proven by respondent, petitioners conceded numerous adjustments determined by respondent to be unreported income or deductions to which petitioners were not entitled. To the extent no settlement or concession was made regarding any other item determined