Page:T.C. Memo. 2012-281.pdf/12

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CSE’s financial status, including current figures for bank deposits, loans, payroll expenses, and merchandise sales. She also issued instructions and memoranda to the entire staff. Petitioner, along with Mr. Hovind, was responsible for authorizing all expenditures over $20. Petitioner did not receive wages for her services at CSE.

D. Petitioner’s and Mr. Hovind’s Finances

Although petitioner and Mr. Hovind maintained separate personal bank accounts,[1] there was no distinction between their finances and CSE’s finances.[2] CSE paid petitioner’s living expenses, including room and board, and provided an automobile. Petitioner drafted and signed checks drawn on CSE bank accounts for

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  1. During the years at issue petitioner and Mr. Hovind maintained the following personal bank accounts: (1) from December 23, 1997, through January 25, 2007, an account at First Union National Bank (later Wachovia Bank, N.A., presently Wells Fargo Bank, N.A.) under the name “Mrs. Jo Delia Hovind; Kent E. Hovind” (account 8049); and (2) from December 18, 1997, through January 20, 1999, an account at Sun Trust Bank under the name “Dr. Kent E. Hovind or Jo Delia Hovind” (account 0811). From January 14, 1998, through January 16, 2001, petitioner maintained an account at the Peoples Bank under the name “Jo Hovind” (account 5201).
  2. For example, on a date not apparent from the record Mr. Hovind’s mother died, leaving him an inheritance. Mr. Hovind deposited the inheritance into a CSE account.