- 12 - First, to rebut the adverse inferences that might be drawn from the fact that Mr. Parsons often took cash from Cedar Hill’s proceeds without recording it on the pink sheets as a personal draw, petitioners contend that they understood the pink sheets to function merely as a “snapshot” of the day’s business activity, so that cash removed after the business day need not be reflected on the pink sheets. Thus, the argument goes, Mr. Parsons recorded cash he withdrew for personal use from the registers during business hours but did not believe it was necessary to record cash taken on the following day before Cedar Hill’s proceeds were deposited into its bank account. Besides finding it implausible that a college-educated, successful businessman could believe this, we note that petitioners’ own actions are inconsistent with this explanation. Mrs. Parsons testified that she would on occasion remove cash for petitioners’ personal use in the evenings at home when she was performing her bookkeeping tasks for Cedar Hill, and that these withdrawals were recorded as personal draws on the pink sheets. If petitioners believed the pink sheets were to function only as a “snapshot” of the business day, Mrs. Parsons’ after-hours withdrawals would not need to be recorded.4 4 Petitioners’ “snapshot” theory is also different from the explanation initially provided by petitioners’ accountant to respondent’s revenue agent in the course of the audit. As (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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