Philip E. Parsons and Karen Parsons - Page 12




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               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...)           





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