Tax Court Upholds Taxation of Money Laundering as U.S. Trade or Business of Nonresident Aliens

On September 26, 1988, in the case of Santiago Perez v. Commissioner of Internal Revenue, the United States Court upheld as correct a termination and jeopardy assessment under I.R.C. additions to tax for taxable years 1983 and 1984, arising from illegal money laundering services performed in South Florida by Santiago Perez, whose legal residence and prinicipal office were located in Bogota, Colombia.