Page:T.C. Memo. 2012-281.pdf/36

From Wikisource
Jump to navigation Jump to search
This page needs to be proofread.

[*36] 

when Mr. Hovind told her to do so. She also testified that she did not draft the checks and that she only signed blank checks.[1]

We find petitioner’s testimony to be self-serving, unreliable, and not credible. Petitioner had signatory authority and exercised control over CSE’s accounts. She drafted and signed checks drawn on CSE accounts during the years at issue. Her involvement with CSE during the years at issue was extensive. Petitioner supervised employees, made executive decisions in Mr. Hovind’s absence, and maintained some records.

The record also contains ample credible evidence that petitioner managed CSE’s financial affairs,[2] including evidence that petitioner reconciled CSE’s accounts and advised Mr. Hovind on financial matters. In affirming petitioner’s and Mr. Hovind’s criminal convictions, the U.S. Court of Appeals for the 11th Circuit stated that “[c]ompany documents and records of the transactions

___________

  1. With respect to the checks drawn on account 1872 for the period from November 29, 2002, through December 29, 2006, it appears that Mr. Hovind signed all of the checks. It is unclear whether petitioner, Martha Harris, a CSE employee, or Mr. Hovind drafted the checks. With respect to the checks drawn on account 8656 between July 30, 1999, and January 30, 2004, it appears that petitioner drafted and signed most of the checks.
  2. Special Agent Schneider testified that petitioner was Mr. Hovind’s “righthand man” and that petitioner controlled CSE’s finances and made all business decisions in Mr. Hovind’s absence.