On Wednesday, I attended an all-day continuing education seminar put on by the Nevada Society of Enrolled Agents. This happened to be the annual IRS liaison meeting, and a hot topic was the indictment of Randolph Goldberg. This was especially true given we were treated to a presentation from local IRS Criminal Investigation (CI) agents. (They did not state anything about this case, of course.)

Mr. Goldberg is accused of keeping two bank accounts. There’s nothing wrong with that. However, he’s being accused of only including the deposits from one of the two accounts on his tax returns. Adding to his troubles is that he’s being accused of “structuring” bank deposits. Structuring is adjusting your bank deposits of cash deliberately so as to avoid currency transaction reports (CTR). If you make a deposit of $10,000 or more of cash, the bank will file a CTR. Mr. Goldberg is being accused of structuring bank deposits 147 times.

Mr. Goldberg is accused of four counts of tax evasion and five counts of structuring. He pleaded not guilty to the charges on Thursday. He was released on his own recognizance; his next hearing is in late November.

It takes effort to get in trouble with CTRs — so many of them a year are issued. Interestingly enough, one of the tidbits that CI gave us is that in August of this year there were 808 Suspicious Activity Reports (SARs) received in Las Vegas. (I believe, but am not 100% certain, that is the number issued by banks and casinos here in Las Vegas.) IRS CI told us that they have investigated or are investigating every one of the SARs.

SARs are issued when a bank or casino thinks their may be suspicious activity going on. For example, a SAR is likely to be issued if you make an $8,000 cash deposit in the morning and another $3,000 cash deposit in the afternoon. People don’t like dealing with CTRs because their issuance usually takes an extra 30 minutes at the bank. Assuming that one or more SARs lead to the investigation of Mr. Goldberg (which is very likely), he could spend far longer than 30 minutes at ClubFed.