Lee F. Haney, Sr., and Jean C. Haney, a.k.a. Jeanie Haney - Page 35




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          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 of                  







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