John W. Singleton, A/K/A John Westly, A/K/A John Sinkler v. Commissioner of Internal Revenue, John W. Singleton

OPINION OF THE COURT

This appeal from a decision of the United States Tax Court requires us to analyze the effect of a pat-down search by a United States Customs security officer of an aircraft passenger boarding an international flight. The search disclosed $20,000 in cash in the taxpayer’s suit coat. He was requested to report possession of the money on a Customs Service Form 4790 entitled “Report of International Transportation of Currency or Monetary Instruments.” 1 A subsequent examination of the completed form by a special agent of the Intelligence Division of the Internal Revenue…