As a result, the fact that Form 8300 may provide the Internal Revenue Service (IRS) with a powerful investigative tool has been somewhat overshadowed. Section 60501 requires all persons engaged in a trade or business to report cash transactions in excess of $10,000 to the IRS by filing Form 8300 within 15 days of the cash transaction. Form 8300 requires disclosure of detailed facts about the transaction, including the date and amount of the transaction and the name, address, employer identification number, passport number, Social Security number, and business or occupation of the payor. Much of the controversy about Form 8300 has centered on the IRS position that the obligation to file the form extends to lawyers actively engaged in defending criminal cases. The organized bar has strongly opposed this on the ground that the filing requirement constitutes a major intrusion into the confidentiality of the attorney-client relationship. There are both civil and criminal penalties for failing to file Form 8300; consequently, many criminal defense lawyers file the form to report the receipt of cash but do not disclose the identity of the client-payor. Thus far, however, the IRS has made it clear that it does not consider this approach sufficient compliance with Section 60501 and has instituted test case litigation against two criminal defense law firms in New York. The issue of possible money laundering charges for failing to file Form 8300 is discussed.