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SINGLETON v. C. I. R.

No. 78-2599.

606 F.2d 50 (1979)

John W. SINGLETON, a/k/a John Westly, a/k/a John Sinkler v. COMMISSIONER OF INTERNAL REVENUE, John W. Singleton, Appellant.

United States Court of Appeals, Third Circuit.

Decided September 28, 1979.

Attorney(s) appearing for the Case

Richard A. Levine (argued), Laurence Goldfein, Ira L. Tilzer, Roberts & Holland, New York City, for appellant.

M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Robert A. Bernstein, Francis J. Gould (argued), Tax Div., Dept. of Justice, Washington, D. C., for appellee.

Before ALDISERT, ROSENN and GARTH, Circuit Judges.

OPINION OF THE COURT

PER CURIAM.

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...

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