Lee F. Haney, Sr., and Jean C. Haney, a.k.a. Jeanie Haney - Page 25




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          petitioners.  This argument is inconsistent with petitioners’               
          assertion that the cash received from the cashed checks was not             
          retained by petitioners but was entrusted to Steelman for an                
          alleged petty cash fund.  Because no records were maintained                
          regarding the amount, timing, or source of cash that petitioner             
          added to his personal safe, and because petitioners’ testimony              
          regarding the cash transactions was inconsistent and                        
          unpersuasive, petitioners have not met their burden of proving              
          that respondent erred in including these cash deposits as                   
          additional income to petitioners in the notice of deficiency for            
          2002.                                                                       
          Additional Employee Embezzlement Account Deduction                          
               Petitioners assert that they are entitled to an increased              
          deduction for cash funds allegedly embezzled by Steelman in 2000,           
          before her embezzlement scheme was discovered.  For the reasons             
          stated above, we do not believe that Steelman had access to the             
          cash that Mrs. Haney received upon cashing the checks received by           
          Flair Enterprises.  Petitioners are not entitled to a deduction             
          for their Employee Embezzlement Account beyond what respondent              
          has already allowed.                                                        
          Claimed Deductions Disallowed                                               
               Respondent disallowed many flowthrough deductions claimed by           
          petitioners because they related to personal expenses of                    








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