Other People's Money
Joel S. Newman
Wake Forest University - School of Law
October 9, 2009
Tax Notes, Vol. 125, No. 1, p. 137, October 5, 2009
Wake Forest Univ. Legal Studies Paper No. 1487530
In informal banking arrangements such as cundinas and tandas, the “banker” will have an unexplained fund of money, which the IRS will presume was acquired in a taxable way. Drug dealers and embezzlers often have the same problem. The informal bankers, with adequate records, can rebut the presumption. However, it is too bad that they have to be analogized to criminals in order to do so.
Number of Pages in PDF File: 6Accepted Paper Series
Date posted: October 15, 2009 ; Last revised: March 22, 2010
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