The debtors in the case were husband (now deceased) and wife, who we will refer to as Curtis and Barbara and together as the Coneys. Curtis was a lawyer operating through a sole owner S corporation. The tax liabilities arose from his law practice. Without going through all the details, the Coneys had a large amount of taxable income coming from the law firm. They apparently reported the income, but went to extraordinary lengths to prevent the IRS from discovering available assets to pay their resulting large tax liabilities. In negotiating with the IRS regarding payment of the liabilities, the debtors committed to turn over certain fees as received. They failed to turn over one large fee. Furthermore, the law firm "engaged in a high volume of cash transactions." Some of the cash proceeds it received were used to make illegal payments to runners for the law firm. In order to disguise the withdrawal of the cash, the husband debtor instructed staff to draw checks under the $10,000 reporting requirement to obtain the cash to pay the runners, thereby avoiding the CTR reporting requirement.
Things unraveled from there. Husband debtor was charged with
(a) one count of conspiracy to structure financial transactions in violation of 31 U.S.C. § 5324 from 1997 to 2001, (b) ten counts involving ten separate incidents of structuring financial transactions in violation of 31 U.S.C. § 5324 from 1997 to 2001, and (c) one count of obstruction of justice for attempting to influence [a staff member's] grand jury testimony.Barbara was charged with "one count of obstruction of justice for attempting to influence [the staff member's] grand jury testimony.
The Coneys thereafter pled to all charges. [I am sure there is a story there, but it is not given in the case.]