During her testimony, when the evidence clearly testified about the existence of unreported income, the defendant claimed, as did the defendant, that the responsibility for this lies with CPA Dotan. However, this argument was also rejected above.
I will add that the contradiction between her statements in the police interrogation and her testimony in court as to who managed the rental registration in the motel also has implications for the defendant's credibility. The same is true of the defendant's testimony on the subject of cash deposits, which she explained as stemming mainly from the sale of vehicles (a claim for which no support was found). The claim that she did not know what part of the money came from the rental, since she married so that someone else would handle the accounts, is inconsistent with the defendant's extensive involvement in the management of the motel and with the picture that has been painted so far in her case.
In the framework of the question of the mental element, the defense argued that the defendant relied on the defendant's reports to the accountant and therefore the mental element of the offenses under section 220 of the Ordinance does not exist in her case . I am of the opinion that this argument should be rejected. The starting point in the defendant's case is the above conclusion that the defendant was well aware of the hotel's activity. From this starting point, the question of her awareness of the reports should be examined further.
The defendant signed the reports submitted by CPA Dotan. It should be remembered that in 2015 and 2016, for which rental income of NIS 4, NIS 340 and NIS 0 were reported (respectively), the motel was registered under N.K. Building, which is owned by the defendant. As for the years 2017 and 2018, when she was asked whether she was aware of the content of the reports, the defendant's answer was vague ("I don't know if I am aware"), far from an unequivocal denial of awareness on her part. When asked whether it was true that she had just signed the reports, her answer was "there is a situation", i.e., an answer far from shouting her innocence. These answers did not convince me that the defendant was only a rubber stamp and was not aware of the content of the reports, which did not reflect the defendants' income from the motel. In addition, the defendant admitted that she felt the need to understand things herself and therefore met with the accountant from time to time and asked him "20 questions". These statements by the defendant weaken her claim that she was not aware of the content of the reports.