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#179390 - 04/13/04 08:53 PM CTR Multiple Parties
Jello Offline
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Jello
Joined: Feb 2003
Posts: 162
I have a strange situation that has led to a CTR question I don't quite know the answer to. Here are the facts of the situation:

Father and Son have a business account that is just a DBA account with both names as owners and the Father's SSN on the account.
Father and Son come in together and deposit $9,000 cash into the DBA account. Father also deposits $2,000 into his personal account with only his name on it, and Son also deposits $1,000 into his personal account with only his name on it.

I am convinced we have met the CTR threshold, but have no idea if this should be documented on 1 CTR or 2. I can't see doing 2 because then the $9,000 deposit would be reflected on 2 different CTR'S, but I can't figure out how to do it on one, since there is a part of the transaction that only benefits one and not the other. Anyone else ran into anything like this before?
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#179391 - 04/13/04 09:44 PM Re: CTR Multiple Parties
GreatBlue Offline
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GreatBlue
Joined: Feb 2003
Posts: 2,362
Colorado
Jello,
You say that both the son and father are "owners" of the DBA account, but that it uses the father's SSN. Is the son really an owner, or just an authorized signer? Usually a business owned by 2 people (with the exception in some states of spouses) has to be owned by a partnership.

Son only conducted $10,000 worth of transactions, and even if he is in fact an owner of the DBA account, only $10,000 was deposited on his behalf, so I would not report his $1,000 transaction. (If you aggregate it with either the other transaction he conducted or the other transaction that benefit him you still only have a $10,000 transaction.) I would report only the $9,000 "joint" deposit and the $2,000 father's deposit.

If they are both actually owners of the DBA account, I would list father in Part A with the DBA, and son in a second part A, then I would check "conducted on own behalf" in part B. The amount would be $11,000.

If the father really is the sole owner of the DBA, then I would still put his information in Part A with the DBA, and I would mark "conducted on own behalf" in Part B. Then I would also list the son in a separate Part B.
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#179392 - 04/13/04 09:48 PM Re: CTR Multiple Parties
Jello Offline
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Jello
Joined: Feb 2003
Posts: 162
Thanks so much for the response GreatBlue. On our system both the Father and Son are listed as "owners" of the DBA account, but we use the Fathers SSN for interest reporting. Also, I had rounded off my numbers in my scenario to make it a little easier, but in fact the Son also did deposit over $10,000 between the DBA account and his personal account.
I think the whole thing is just a mess
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#179393 - 04/13/04 09:51 PM Re: CTR Multiple Parties
GreatBlue Offline
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GreatBlue
Joined: Feb 2003
Posts: 2,362
Colorado
Wow! That is a mess! I would probably just do one CTR for the whole thing ($12,000), list each in a separate part A, and mark "conducted on own behalf", but I'm not totally confident of that.
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#179394 - 04/13/04 09:56 PM Re: CTR Multiple Parties
Jello Offline
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Jello
Joined: Feb 2003
Posts: 162
That's exactly what I was thinking. I think it has to be only 1 CTR, and so the only way to do that is to use the multiple persons, but what concerns me is the individual accounts.... At any rate, that is likely what we will end up doing, I really appreciate the feedback!
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#179395 - 04/14/04 01:47 AM Re: CTR Multiple Parties
JacF Offline

Power Poster
Joined: Nov 2001
Posts: 6,719
PA
I agree that all three transactions should be reported on a single CTR, as Great Blue described.

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#179396 - 04/14/04 11:17 AM Re: CTR Multiple Parties
Skittles Offline
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Skittles
Joined: Sep 2002
Posts: 13,965
TN
I do have a question, though. Is this set up as a sole proprietorship with a dba or a partnership with a dba?
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#179397 - 04/14/04 01:51 PM Re: CTR Multiple Parties
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
To piggyback on Skittles' question, you've said that you use the father's SSN for interest reporting.

If this is an SP with Junior as authorized signer, you're OK. But if there are joint owners, this is a partnership, and if this is a checking account, it cannot be interest-bearing.

Aren't you glad you asked the original question?
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