I am having a little bit of a confidence issue on this case. A husband and wife come in together and withdraw a sum of money each out of their own IRA accounts. The aggregate between the two individuals exceeds $10,000 but the individual transactions themselves are less than $10,000. I do not aggregate these transactions simply because the two individuals came in together and sat at the same desk do I?

As the transactions were not by the same person or on behalf of the same person, I would not...

As I often do, I agree with Ken. Because IRAs are distinctively individual arrangements, I would not infer any common interest in them between spouses irrespective of the fact that one spouse may be the beneficiary of the other. The transactions were each done by one individual on his or her own individual behalf. No CTR.

Thank you both!