Philip E. Parsons and Karen Parsons - Page 14




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          based entirely on their self-serving testimony and are                      
          unconvincing.  Moreover, this failure purportedly caused by                 
          miscommunication occurred 2 years in a row.  The amounts reported           
          on petitioners’ returns as Mr. Parsons’ salary or “draw” from               
          Cedar Hill were $25,000 and $30,000 in 1987 and 1988,                       
          respectively.  Petitioners have conceded that the actual amounts            
          they received from Cedar Hill in those years were $82,106 and               
          $65,957, respectively.  We do not believe that petitioners could            
          continue to believe that their accountant was successfully                  
          tracking all the cash they were taking from Cedar Hill, via Mrs.            
          Parsons’ checking account records, which were never furnished to            
          the accountant, or otherwise, in light of the size of the                   
          discrepancies in the figures reported on the return and the                 
          amounts actually taken in each year.  Finally, respondent has               
          reconstructed personal expenditures in each year (which                     
          petitioners have conceded) that substantially exceed the net                
          balance plus deposits into Mrs. Parsons’ checking account,                  
          creating the clear inference that significant amounts of cash               
          taken from Cedar Hill by Mr. Parsons were not deposited into the            
          account, as petitioners contend, but spent directly on personal             
          expenditures.  Accordingly, even if SMR had been provided with              
          Mrs. Parsons’ checking account records, it would not have been              
          able to reconstruct all of Mr. Parsons’ diversions from Cedar               
          Hill.                                                                       





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