In 2003, he received a $2 million bonus payment from Delta Currency Trading, LLC, one of several corporations set up to market and advise the tax shelters. The payment was reported on Form 1099 for 2003, but Chai did not include the amount in taxable income. He took the position that it constituted the return of capital from his tax shelter investments. Chai's 2003 tax return also showed an overall loss of $11.5 million, consisting mostly of tax shelter partnership losses.