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#865607 - 12/04/07 03:47 PM CTR- Sole Proprietorships
ccman Offline
Platinum Poster
Joined: Sep 2007
Posts: 918
In completing a CTR on a sole proprietorship should we follow the instructions on the 104 or the ruling we came across sited as FIN-2006-R003? The ruling and Q & A says to report two Sec. A's for a sole proprietorship. Could the ruling be addressing another form of organization. My understanding is that a sole proprietorship is just that. The ruling also says that the "mulitple persons" box in Item 1 should be checked.

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#865612 - 12/04/07 03:49 PM Re: CTR- Sole Proprietorships ccman
ktac MITCH Offline
Diamond Poster
ktac MITCH
Joined: May 2005
Posts: 1,813
Giant side of TX
There are previous threads on this topic, and yes it makes no sense given the instructions and other info concenring seperate legal entities (contract law).
BUT - FinCEN wants to see the DBA as a seperate person from the real person = multiple persons = with a sec A for the person and a sec A for the DBA.
My opinions are just that, and might be worth what you paid for them.

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#865785 - 12/04/07 05:32 PM Re: CTR- Sole Proprietorships ktac MITCH
CantBeShocked Offline
Gold Star
Joined: Apr 2006
Posts: 260
I also understand that you complete the CTR this way for BOTH cash ins as well as cash outs / withdrawals conducted by the owner of a DBA.

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