- 35 - company petty cash fund during the embezzlement investigation, but now allege, as discussed earlier, that Steelman maintained a petty cash fund, into which all the cash from the cashed checks was placed, and that Steelman took that money with her when she left. Petitioners developed this argument only when faced with substantial income tax deficiencies related to the unreported income represented by the cashed checks. The belated, inconsistent, and implausible representations made by petitioners are evidence of petitioners’ fraudulent intent. Mrs. Haney regularly cashed checks from noninsurance customers and business associates but deposited checks from insurance customers. We are convinced that this pattern was a deliberate scheme to report only the income that was easily traceable because of reporting requirements applicable to the payors. We conclude that petitioners’ statements and testimony regarding the cash transactions and the cash kept on hand by them personally were false. Petitioners’ last-minute claims that all cash received by Mrs. Haney at the bank was given to Steelman, who then stole it, is particularly unconvincing. To the contrary, we believe that petitioners have fabricated this argument as a defense to their own wrongdoing in underreporting income and overstating deductions. The evidence in this case establishing the fraudulent intent of each petitioner with regard to their understatements ofPage: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 NextLast modified: November 10, 2007