- 14 - 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.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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