The Bank Secrecy Act (“BSA”), Currency
Reporting Requirements & Responding to
Governmental Inquiries
Presented By:
Charles M. Meadows, Jr., J.D., C.P.A.
Michael A. Villa, Jr., J.D., LL.M.
and
Max M. Wayman, E.A., CFE
901 Main Street, Suite 3700
Dallas, TX 75202
214.744.3700 800.451.0093
fax 214.747.3732
[email protected]
[email protected]
www.meadowscollier.com
Copyright © Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P. All rights reserved.
Two Common Reporting
Requirements for Business Owners
We will focus our attention on two common currency
reports that account for many potential violations for
small business owners:
(1)
Currency Transaction Reports, FinCEN
Form 104, and
(2)
Reports of Currency Received in a Nonfinancial Trade or Business, FinCEN/IRS
Form 8300.
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Why do the BSA Regulations Matter to
Legal and Accounting Advisors?
• If you are advising a client who is forming or operates a
business entity that handles “currency”, or a client who is
expecting cash gifts, you are in an ideal position to advise
your client of the general reporting requirements and
consequences for failing to report properly.
• Many of the examples we will discuss could have been
avoided if these individuals had been advised prior to the
alleged BSA violations.
• In addition, some of your clients may be entitled to an
exemption from the reporting requirements and should be
advised on these issues upon forming their business entity.
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BSA Enforcement
Amendments to the BSA by the U.S. Patriot Act in
2001 increased reporting requirements. Therefore,
enforcement of alleged BSA violations has increased
as well.
• In 2000, banks filed 162,720 SARs nationwide, and
10,119 SARs in Texas
• In 2009, banks filed 720,309 SARs nationwide, and
45,425 SARs in Texas
― See FinCEN SAR Activity Review – By the Numbers,
Issue 14, (June 2010)
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Suspicious Activity Report Filing Trend for the State of Texas For
the Period
April 1, 1996 through December 31, 2009
50,000
45,425
43,310
45,000
38,036
40,000
36,097
32,561
35,000
30,000
23,231
23,095
25,000
20,000
17,203
17,611
13,426
15,000
10,119
10,000
5,000
0
1996 1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
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2009
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Characterizations of Suspicious Activity for the State of Texas
For the Period April 1, 1996 through December 31, 2009
10%
Check Fraud
36,589
Additional Characterizations
32,370
9%
47%
BSA/Structuring/
Money Laundering
164,769
Other
30,717
9%
Check Kiting
10,954
3%
Consumer
Loan Fraud
17,258
5%
Counterfeit Check
15,879
4%
Mortgage
Loan Fraud
15,866
4%
175
Bribery/Gratuity
202
Counterfeit Credit/Debit Card
False Statement
19,701
6%
Identity Theft
9,444
3%
Terrorist Financing
458
Computer Intrusion
576
Counterfeit Instrument (Other)
1,423
Commercial Loan Fraud
2,195
Unknown/Blank
2,374
Mysterious Disappearance
2,618
Misuse of Position or Self - Dealing
3,085
Debit Card Fraud
3,263
Credit Card Fraud
4,222
Defalcation/Embezzlement
5,852
Wire Transfer Fraud
5,927
0
2,000
4,000
6,000
8,000
Note: The pie chart represents the top nine characterizations plus additional characterizations in total. An
individual SAR may cite more than one characterization. Hence, the number of characterizations detailed here
significantly exceeds the total number of SARs.
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Examples of Unexpected Recent
Enforcement of the BSA
• Increased enforcement ensnares unwitting bank customers
and results in parallel civil and criminal investigations.
– Young couple received $40,000 in cash at their Greek wedding
and deposited in sums under $10,000.
– The IRS seized $400,000 from bank accounts belonging to New
York restaurant owners.
– IRS seized $330,000 from three Dallas taxi cab companies on
suspicion of structuring.
– IRS seized $240,000 from motel owners who deposited under
$10,000 on a regular basis.
 Even if the source of funds is from a legitimate source and taxes
were paid, there can still be a civil and/or criminal penalty for the
structuring alone.
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Currency Transaction Reports, FinCEN
Form 104
• Under 31 U.S.C. § 5313, “financial institutions” must file a
FinCEN Form 104 Currency Transaction Report (“CTR”) with
the IRS reporting any deposit or withdrawal which involves a
“transaction” in “currency” in excess of $10,000.
• “Financial institution” includes, among others, banks, brokers
and dealers in securities, and money service businesses.
• “Transaction in currency” means the physical transfer of
currency from one person to another.
• “Currency” includes coin and paper money of the U.S. or of
any other country.
– 31 CFR § 103.11
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Prohibition on Avoiding
the Currency Reports
31 U.S.C. § 5324 provides that no person shall, for the
purpose of evading the reporting requirements of § 5313:
(1) Cause or attempt to cause a financial
institution not to file a CTR;
(2) Cause a financial institution to file a CTR that
contains a material omission or misstatement; or
(3) Structure or attempt to structure a transaction to
avoid a reporting requirement.
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Civil & Criminal Penalties for
Avoiding Form 104 Currency Reports
• A civil penalty of up to the amount of currency involved in the
transaction is imposed on anyone who causes or attempts to
cause a bank to fail to file a CTR. 31 U.S.C. § 5321(a)(4)
• A criminal fine of not more than $250,000 and/or
imprisonment of not more than 5 years may also be imposed.
31 U.S.C. § 5324(d)(1)
• The criminal fine can be increased to $500,000 and/or
imprisonment of 10 years in cases involving the violation of
other laws or a pattern of activity involving more than
$100,000 in a 12 month period. 31 U.S.C. § 5324(d)(2)
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Criminal Prosecutions
•
For criminal prosecutions under § 5324, the government only has to prove that the
defendant:
–
–
–
knowingly structured a currency transaction
knew of the reporting requirement
structured the transaction to evade the report
•
Post 1994, the government does not have to prove that the defendant knew that structuring
was illegal.
•
Circumstantial evidence can be sufficient to establish that the defendant intended to evade
reporting requirements. U.S. v. MacPherson, 424 F.3d 183, 191 (2d Cir. 2005)
•
“The fact of structuring may well support the inference that the defendant acted purposefully
to avoid the bank’s CTR obligations”
–
•
United States v. Warner, 2006 WL 2583722 at *24 (N.D. Ill. Sep. 7, 2006) (citing United States v.
Cassano, 372 F.3d 868, 879 (7th Cir. 2004), vacated on other grounds by Cassano v. U.S., 543 U.S.
1109 (2005)
What do these cases mean?
–
Currency depositors could possibly be convicted simply if the government demonstrates a consistent
pattern of deposits under the reporting requirement which by itself may demonstrate that the
defendant knew of the reporting requirement.
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General Rules on Exemption
•
In an effort to reduce the number of CTR filings, Treasury has created
exemptions from CTR filing requirements for transactions that have no real
use to law enforcement agencies. 31 U.S.C. § 5313(d)-(e) and 31 CFR
§103.22(d)
•
Generally, no bank is required to file a CTR with respect to any transaction
in currency between an “exempt person” and such bank. 31 CFR
§103.22(d)(1).
– FinCEN Form 110 (Designation of Exempt Person)
•
Exempt transactions may include:
– Transactions between two separate banks
– Transactions between banks and ordinary retail businesses, such as:
 Restaurants
 Grocery stores
 Department stores
 Gas stations
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Exempt Person
31 CFR § 103.22 (d)(2)
•
“Exempt person” includes, among others, banks, agencies of the U.S.,
states and political subdivisions.
•
There is also a “catch all” definition for commercial enterprises and payroll
customers under 31 CFR § 103.22(d)(2)(vi), (vii).
•
Any other commercial enterprise to the extent of its domestic operations, if
the following requirements are satisfied:
 Maintained a transaction account at the bank for at least 12 months
 Frequently engaged in transactions in currency in excess of $10,000, and
 Must be incorporated in or licensed to do business in the United States.
– Ineligible businesses:
–
–
–
–
Sale of motor vehicles of any kind
Practice of law, accountancy, or medicine
Auctioning of goods
Real estate brokerage. 31 CFR § 103.22(d)(6)(viii)
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Initial Designation
of Exempt Person
• The bank must file FinCEN Form 110 in order to seek
exempt person status.
• The designation must be made separately by each bank
that treats the person in question as an exempt person
• 31 CFR 103.22(d)(3)(i)
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Form 8300: Reports of Currency Received in a
Non-financial Trade or Business
31 U.S.C. § 5331 requires that:
(1) Any person who is engaged in a trade or business,
and
(2) Who, in the course of such business, receives more
than $10,000 in coins or currency in 1 transaction
(or 2 or more related transactions), shall file a
report with respect to such transaction(s) with the
FinCEN.

26 U.S.C. § 6050I contains an identical reporting requirement

31 U.S.C. § 5331 and 26 U.S.C. § 6050I can both be satisfied by
filing the FinCEN / IRS Form 8300. 31 CFR § 103.30(a)(1)(ii);
§103.30(e).
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Definitions Related to Form 8300
• “Currency” includes the coin and currency of the U.S. or of any other
country which are customarily used and accepted as money in the
other country.
• Solely for purposes of 31 U.S.C. § 5331 and 26 U.S.C. § 6050I,
“currency” also includes:
– A cashier’s check, bank draft, traveler’s check or money order having a
face amount of less than $10,000 that is:
(a)
received in a “designated reporting transaction”, or
(b)
received in any other transaction in which the recipient knows that the
instrument is being used in an attempt to avoid reporting the
transaction. 31 CFR § 103.30(c)(1); 26 CFR § 1.6050I-1(c)
– A “designated reporting transaction” is a retail sale of a consumer
durable, a collectable or a travel or entertainment activity
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Definitions Related to Form 8300
• “Trade or Business” has the same meaning as it does
under 26 U.S.C. § 162. If the receipt of currency is not in
the course of the person’s trade or business, a Form
8300 is not required.
― 31 CFR § 103.30(c)(11), (d)(2)
• “Transaction” includes (but is not limited to) the sale of
(a) goods or services, (b) real or personal property, and
(c) intangible property.
– 31 CFR § 103.30(c)(12)(i)
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Related Transactions
“Related transactions” means any transaction conducted
between a payer (or its agent) and a recipient of
currency in a 24-hour period
• In addition, transactions conducted between a payer (or its
agent) and a currency recipient during a period of more
than 24 hours are related if the recipient knows or has
reason to know that each transaction is one of a series of
connected transactions.
• 31 CFR § 103.30(c)(12)(ii)
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Filing Requirements
• Form 8300 must be filed within 15 days after currency is
received in the reportable transaction. 26 CFR § 6050I1(e)(1).
• Receipt of multiple payments:
– The Form 8300 must be filed within 15 days of the date on which
the total payments received exceeds $10,000
• If the initial payment is $10,000 or less, then the recipient must
aggregate the initial payment and all subsequent payments made
within one year and the report must be filed within 15 days of the
date on which the payment that causes the total aggregate payment
to exceed $10,000 is received.
– 31 CFR § 103.30(b).
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Form 8300 Requirements
• Name, address, and taxpayer identification number of the
person who paid with currency.
• Identical information is required regarding the person on
whose behalf the transaction was conducted (if this person is
different from the payer). 31 U.S.C. § 5331(b)(2); 26 CFR §
6050I-1(e)(2).
• The filing business must verify the identity of the person.
• Retained for five years after the date of the filing. 31 CFR §
103.30(e)(3).
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Who Files Form 8300?
•
The business that receives the currency.
•
Any person who is collecting money for the account of another, then the person collecting
the money must file a Form 8300.
–
•
For example, a person who collects delinquent accounts receivable for a car dealership must file a
Form 8300 even though the money must be turned over and credited to the car dealership. 31 CFR
§ 103.30(a)(2)
A person who is acting as an agent for another person and receives more than $10,000 from
a principal. 31 CFR § 103.30(a)(3)(i).
–
The agent does not have to file Form 8300 if he uses all of the currency within 15 days in a currency
transaction that is otherwise reportable by the ultimate recipient of the money.
–
Example: Charlie Client gives Andrew Attorney $75,000 in currency to purchase real estate for Mr.
Client. Within 15 days, Mr. Attorney purchases the property for currency from a third party seller.
 Mr. Attorney must disclose the name, address, and taxpayer identification number of the
principal, Charlie Client, to the third party recipient of the currency so that the recipient can
complete Form 8300.
– 31 CFR § 103.30(a)(3)(iii)
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Anti-Structuring Laws
Related to Form 8300
No person shall for the purpose of evading the return
requirements of this section:
(A) cause or attempt to cause a trade or business to fail to file a
Form 8300;
(B) cause or attempt to cause a trade or business to file a Form
8300 that contains a material omission or misstatement of fact;
or
(C) structure or assist in structuring, or attempt to structure or
assist in structuring, any transaction with one or more trades
or businesses, to avoid the Form 8300 reporting requirement.
 26 U.S.C. § 6050I(f)(1)
 31 U.S.C. § 5324(b)
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Civil Penalties Relating to Form 8300
• $50 per form for failure to file a timely and/or correct Form 8300.
Maximum fine of $250,000 per calendar year for all transactions. 26
U.S.C. § 6721(a).
• Negligent violations: Civil penalty of not more than $500.
– If there is a “pattern of negligent activity”, an additional fine of up to
$50,000 may be imposed. 31 U.S.C. § 5321(a)(6).
• Willful failure to file: Civil penalty of not more than the greater of the
amount (not to exceed $100,000) involved in the transaction (if any)
or $25,000. 31 U.S.C. § 5321(a)(1).
• Intentional disregard: The greater of (a)$25,000 or (b) the amount of
cash received up to $100,000. 26 U.S.C. § 6721(e)(2)(C).
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Criminal Penalties
Relating to Form 8300
Criminal penalties:
•
Willful failure to file a Form 8300 is a felony punishable by a maximum of 5
years in prison and/or a fine of $25,000 ($100,000 in the case of a
corporation) may be imposed. 26 U.S.C. § 7203.
•
Filing a false Form 8300 or assisting in the filing of a false Form 8300 are
felonies punishable by a maximum of 3 years in prison and/or a fine of
$100,000 ($500,000 for a corporation) may be imposed. 26 U.S.C. § 7206.
•
Title 31 carries separate penalties for willfully violating Form 8300 reporting
requirements and can result in:
– A criminal fine up to $250,000 and/or imprisonment of 5 years, or
– A fine up to $500,000 and/or imprisonment of up to 10 years in aggravated cases
involving the violation of other laws or a pattern of activity involving more than
$100,000 in a 12 month period.
 31 U.S.C. § 5322.
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Return Preparer
• Tax Return Preparer
– Any person who prepares for compensation, or who employs one or
more persons to prepare for compensation, any return of tax imposed
by this title or any claim for refund of tax imposed by this title. 26 U.S.C.
§ 7701(a)(36)(A)
– What should a tax return preparer be mindful of when receiving a
governmental inquiry via summons or subpoena?
• Circular 230 Consideration When Responding to the IRS.
– Section 10.22 Diligence as to Accuracy:
 A practitioner must exercise due diligence in determining the correctness of
oral or written representations made to Treasury.
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Summons Authority
• The IRS may issue a summons for the purpose of:
(1) Ascertaining the correctness of any return;
(2) Making a return where none has been made;
(3) Determining tax liability;
(4) Determining the liability of any transferee or fiduciary; and
(5) Collecting such tax liability.
• The IRS may use a summons to:
– Require the appearance of the taxpayers or witnesses to testify; and
– Examine books, papers, records or other data.
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Summons Enforcement
• Government must satisfy four requirements to enforce a
summons:
– Legitimate purpose;
– Information sought may be relevant to the investigation;
– Information sought is not already within the IRS’s
possession;
– Administrative steps required by the Code have been
followed.
 U.S. v. Powell, 379 US 48 (1964).
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“Relevant or Material”
• Does the material sought “throw light upon” the correctness of the
returns?
– Liberally and broadly construed.
• Is the summons overbroad?
– Requests for all records or documents may be overbroad and enforcement
might be limited to specifically itemized requests. U.S. v. Darwin Constr.
Co., 632 F. Supp. 1426 (D. Md. 1986).
• Applicability of § 7525 (tax practitioner privilege) to summons response:
– Does not apply in criminal proceedings.
– Courts have limited its application.
 Does not cover documents written in conjunction with the preparation of a tax
return. U.S. v. KPMG, 237 F. Supp. 2d 35 (DDC 2002).
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Grand Jury Subpoena
• Grand jury’s investigative powers exceed the IRS
summons power.
• Power to issue subpoenas demanding the appearance
of witnesses and the production of documents.
– Grand juries are given broad subpoena power.
– Still must be reasonable in time, breadth, and particularize
the documents it seeks. See In re Grand Jury Subpoena
on Allied Auto Sales, 606 F. Supp. 7 (DRI 1983).
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Subpoena to Targets and Subjects
•
US Attorney’s Manual Ch. 9-11.150
•
Subpoenaing Targets of the Investigation
–
A grand jury may properly subpoena a subject or a target of the investigation and question the
target about his or her involvement in the crime under investigation. See United States v. Wong,
431 U.S. 174, 179 n. 8 (1977); United States v. Washington, 431 U.S. 181, 190 n. 6 (1977); United
States v. Mandujano, 425 U.S. 564, 573-75 and 584 n. 9 (1976); United States v. Dionisio, 410
U.S. 1, 10 n. 8 (1973).
–
However, in the context of particular cases such a subpoena may carry the appearance of
unfairness. Because the potential for misunderstanding is great, before a known "target" is
subpoenaed to testify before the grand jury about his or her involvement in the crime under
investigation, an effort should be made to secure the target's voluntary appearance.
–
If a voluntary appearance cannot be obtained, the target should be subpoenaed only after the
grand jury and the United States Attorney or the responsible Assistant Attorney General have
approved the subpoena. In determining whether to approve a subpoena for a "target," careful
attention will be paid to the following considerations:

The importance to the successful conduct of the grand jury's investigation of the testimony or other
information sought;

Whether the substance of the testimony or other information sought could be provided by other witnesses;
and

Whether the questions the prosecutor and the grand jurors intend to ask or the other information sought
would be protected by a valid claim of privilege.
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Advice of Rights to Targets and Subjects
•
•
US Attorney’s Manual Ch. 9-11.151
Advice of "Rights" of Grand Jury Witnesses
– It is the policy of the Department of Justice to advise a grand jury witness of his
or her rights if such witness is a "target" or "subject" of a grand jury investigation.
– A "target" is a person as to whom the prosecutor or the grand jury has substantial
evidence linking him or her to the commission of a crime and who, in the
judgment of the prosecutor, is a putative defendant. An officer or employee of an
organization which is a target is not automatically considered a target even if
such officer's or employee's conduct contributed to the commission of the crime
by the target organization. The same lack of automatic target status holds true
for organizations which employ or employed an officer or employee who is a
target.
– A "subject" of an investigation is a person whose conduct is within the scope of
the grand jury's investigation.
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Obstruction of Justice
•
Obstruction of Justice is governed by 18 U.S.C. § 1501, et seq.
•
18 U.S.C. § 1512(c):
•
–
Whoever corruptly— (1) alters, destroys, mutilates, or conceals a record, document, or other
object, or attempts to do so, with the intent to impair the object’s integrity or availability for use
in an official proceeding; or
–
(2) otherwise obstructs, influences, or impedes any official proceeding, or attempts to do so,
–
shall be fined under this title or imprisoned not more than 20 years, or both.
In November 2010, an Ohio accountant was sentenced to 11 years in prison for
conspiring to commit mortgage fraud, money laundering, and obstruction of justice.
–
•
U.S. v. Sartain, 2:08-CR-180 (SD OH 2010).
After learning of the IRS investigation into the tax, bank fraud and money laundering
schemes, the accountant and other defendants, engaged in a scheme to obstruct
justice by concealing computers, creating false documents, destroying or altering
evidence, tampering with a witness, and lying to federal and local investigators.
–
The accountant received 12 months for conspiracy to obstruct justice, which was ordered to
run consecutively to his other sentences.
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Accountant as Conspirator
• 18 U.S.C. § 371. Conspiracy to commit an offense or to defraud the
United States.
– If two or more persons conspire either to commit any offense against
the United States, or to defraud the United States, or any agency
thereof in any manner or for any purpose, and one or more of such
persons do any act to effect the object of the conspiracy, each shall be
fined under this title or imprisoned not more than five years, or both.
– If, however, the offense, the commission of which is the object of the
conspiracy, is a misdemeanor only, the punishment for such conspiracy
shall not exceed the maximum punishment provided for such
misdemeanor.
– As seen in the Sartain case, conspiring with a client can possibly result
in criminal charges that are as steep as those levied against the
principals.
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Conspiracy
• A conspiracy is an agreement between two or more persons to join
together to accomplish some unlawful purpose. It is a kind of
“partnership in crime” in which each member becomes the agent of
every other member.
• The following must be proven:
– That the defendant and at least one other person made an agreement
to commit the crime alleged;
– That the defendant knew the unlawful purpose of the agreement and
joined in it willfully, that is, with the intent to further the unlawful purpose;
and
– That one of the conspirators during the existence of the conspiracy,
knowingly committed at least one of the overt acts described in the
indictment in order to accomplish some object or purpose of the
conspiracy.
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Charles M. Meadows, Jr.
Partner
Mr. Meadows, who is Board Certified in Tax Law by the Texas Board of Legal Specialization is
also a CPA, has over 35 years of experience in representing public/private corporations and
individuals in litigation involving tax and white collar legal defense matters.
White Collar Legal Defense: Mr. Meadows has represented entities and individuals accused
of health care fraud, tax fraud, defense contracting fraud, securities fraud, customs violations,
anti-trust violations, money laundering, insurance fraud, environmental fraud, and wire and
mail fraud. He has also successfully defended against large criminal and civil forfeiture cases.
Mr. Meadows has appeared in trials in numerous Federal district courts around the country,
including Illinois, New York, Iowa, Kansas, Georgia, Louisiana, Colorado and all districts in
Texas. He has successfully tried many white collar cases to verdicts of acquittal and resolved
hundreds of other cases without the necessity for trial or indictment.
phone (214) 744-3700
toll-free (800) 451-0093
fax (214) 747-3732
[email protected]
Civil and Criminal Tax Litigation: Mr. Meadows has represented taxpayers in tax
controversies involving corporate and individual income taxes, estate and gift taxes, excise
taxes and the proposed application of civil and criminal penalties under the Internal Revenue
Code. These clients include Fortune 100 corporations, private corporations, non-profit entities,
individuals, and estates and trusts. He has represented taxpayers before the Internal Revenue
Service, Tax Court, Bankruptcy Court and the United States Court of Federal Claims.
In May 2009, Mr. Meadows received the Jules Ritholz Memorial Merit Award from the
American Bar Association Tax Section's Committee on Civil and Criminal Tax Penalties. This
prestigious award recognizes Mr. Meadows' "outstanding dedication, achievement and
integrity in the field of Civil and Criminal Tax Controversies." Mr. Meadows is a frequent
speaker for numerous professional organizations in the legal and accounting professions. He
was admitted to practice in Texas in 1972.
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Michael A. Villa, Jr.
Associate
Mr. Villa’s practice areas are White Collar and Government Regulatory Litigation,
Income Tax Litigation and Commercial Litigation. He concentrates on resolving
Federal tax controversies and white collar crime such as securities, tax and bank
fraud. He represents individuals, closely-held businesses and large corporations
in IRS audits, appeals and litigation. Mr. Villa represents individuals and entities
in business disputes and lawsuits involving fraud, breach of contract, breach of
fiduciary duty, deceptive trade practices act violations, non-compete violations,
business torts and other commercial disputes.
phone (214) 744-3700
toll-free (800) 451-0093
fax (214) 747-3732
[email protected]
Prior to joining the firm in 2007, he worked in Washington, D.C. as a
Congressional intern to U.S. Senator John Breaux (Retired) and worked as an
Associate with a regional law firm in New Orleans, Louisiana. In 2004-2005, he
served as a Judicial Clerk to the Honorable James J. Brady, U.S. District Court,
Middle District of Louisiana.
He received his LL.M. in Taxation from New York University School of Law in
2007, his J.D. and Bachelor of Civil Law from Louisiana State University Paul M.
Hebert Law Center in 2004 and his B.A. from Louisiana State University in 2000.
Mr. Villa was admitted to practice in Texas in 2005. He is also licensed in the
state of Louisiana and has been admitted to the Louisiana Bar.
Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP
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Max M. Wayman, EA, CFE
Max M. Wayman & Associates
Mr. Wayman graduated from Texas Wesleyan College in May 1974 with a Bachelor of Science degree and a
double major in Business and Psychology. He was selected to Who’s Who Among American Students in
American Universities and Colleges, Outstanding College Athletes of America, and Outstanding Young Men of
America. Max began employment with the Internal Revenue Service in August 1974 and was promoted to a
management level within the IRS Collection Division supervising numerous contact section employees.
Mr. Wayman was promoted to Special Agent in the Intelligence Division (later known as Criminal Investigation
Division) in 1977, and received specialized training at Glynco Naval Air Station, Georgia, in areas involving
analyzing financial documents and transactions, search and seizure techniques, arrest techniques, locating
witnesses, locating assets, indirect methods calculations, handgun marksmanship, self defense, and
providing testimony at trial.
He has received numerous awards and recognitions from the IRS such as a Special Achievement Award from
the IRS District Director for contributions to the Criminal Investigation Division. Since leaving the federal
government, additional awards and certifications have been received including selection to the IRS District
Director’s Practitioner Liaison Committee (elected Vice Chairman), National Association of Certified Fraud
Examiners, Enrolled Agent to practice before the Internal Revenue Service, and the Texas Board of Private
Investigators. Representation of clients has included direct involvement in the Whitewater investigation by
Special Prosecutor Kenneth Starr and the Office of Independent Counsel, a one billion dollar embezzlement
of a large bank in South America, international espionage, political scandals, and numerous cases involving
allegations of conspiracy.
phone (817) 569-0200
metro (817) 429-2222
fax (817) 569-0217
[email protected]
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To ensure compliance with U.S. Treasury Regulations governing
tax practice, we inform you that any U.S. federal tax advice
contained in this communication is not intended or written to be
used, and cannot be used, for the purpose of (i) avoiding any
penalties under U.S. Federal tax law, or (ii) promoting, marketing
or recommending to another party any transaction or matter
addressed herein.
Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP
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