- 25 - petitioners. This argument is inconsistent with petitioners’ assertion that the cash received from the cashed checks was not retained by petitioners but was entrusted to Steelman for an alleged petty cash fund. Because no records were maintained regarding the amount, timing, or source of cash that petitioner added to his personal safe, and because petitioners’ testimony regarding the cash transactions was inconsistent and unpersuasive, petitioners have not met their burden of proving that respondent erred in including these cash deposits as additional income to petitioners in the notice of deficiency for 2002. Additional Employee Embezzlement Account Deduction Petitioners assert that they are entitled to an increased deduction for cash funds allegedly embezzled by Steelman in 2000, before her embezzlement scheme was discovered. For the reasons stated above, we do not believe that Steelman had access to the cash that Mrs. Haney received upon cashing the checks received by Flair Enterprises. Petitioners are not entitled to a deduction for their Employee Embezzlement Account beyond what respondent has already allowed. Claimed Deductions Disallowed Respondent disallowed many flowthrough deductions claimed by petitioners because they related to personal expenses ofPage: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 NextLast modified: November 10, 2007