You may be penalized if you do not file your Form 3520 on time or if it is incomplete or inaccurate. Generally, the penalty is 5% of the amount of the foreign gift for each month for which the failure to report continues (not to exceed a total of 25%). "
Filing 3520 has no tax consequencies. But If you play this game of $99,999, you are subjected to up to 25% penalties. I told you clearly to treat related payments as one single payment. Obey the law or take all consequenceis on your own.