Lee F. Haney, Sr., and Jean C. Haney, a.k.a. Jeanie Haney - Page 8




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          Embezzlement by Karen Steelman                                              
               Karen Steelman (Steelman) began her employment with Flair              
          Enterprises as bookkeeper and accountant in 1996 and was trained            
          in office procedures by Phillip Haney and Mrs. Haney.  The                  
          practice of separating noninsurance checks and cashing them                 
          instead of depositing them was established before Steelman joined           
          the company, although no records were kept of such transactions             
          at the time she began her employment.  Steelman was fired in                
          November 2000 when it was discovered that she was embezzling                
          substantial funds from Flair Enterprises during the course of her           
          employment.  Phillip Haney’s wife, Regina Haney (Gina Haney), had           
          been assisting Steelman with the bookkeeping for Flair                      
          Enterprises from May 1999 through November 2000.  When Steelman’s           
          employment was terminated in November 2000, Gina Haney became the           
          primary bookkeeper.                                                         
               Respondent allowed petitioners a deduction of $86,950 in               
          calculating their taxable income for 2000 for money embezzled by            
          Steelman in that year.  The embezzlement deduction was labeled as           
          Employee Embezzlement Account in the “other deductions” section             
          of the Form 1120-S, U.S. Income Tax Return for an S Corporation,            
          filed by Flair Enterprises for the year 2000.                               
               In November 2000, petitioner employed attorney/certified               
          public accountant Jeffrey C. Trent (Trent) to investigate                   
          misappropriation and embezzlement of corporate funds.  Trent                







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