Florida Law Review Volume: 43 Issue: 5 Dated: (December 1991) Pages: 939- 990
Section 6050I of the Internal Revenue Code was enacted to criminalize money laundering and to require recipients of large sums of money ($10,000 cash in a single transaction) to report those transactions.
Since enactment of Section 6050I, the Internal Revenue Service has used the provision as a criminal activity detection device, focused more recently on the criminal bar. Because there is no exemption for lawyers who receive substantial legal fees in cash, lawyers who comply with the provision are in effect rendered government informants against their clients since the required client-identifying information is routinely given to criminal investigatory agencies. This article discusses other statutes regulating money laundering and cash transaction reporting; the legislative history and requirements of Section 6050I; enforcement of the provision; and special problems for attorneys. The author suggests that Congress should amend the statute by adding an attorney exemption and inform the IRS that its current enforcement efforts should be redirected general enforcement. Otherwise, she claims, there will be a serious erosion of voluntary compliance with Federal tax laws. 276 notes
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