[*37]
established that * * * [petitioner] controlled the finances of * * * [CSE] and controlled most of the checks that were cashed.” United States v. Hovind, 305 Fed. Appx. 615, 617 (11th Cir. 2008). On the basis of the entire record, we find that petitioner exercised dominion and control over CSE bank accounts.
Although we reject petitioner’s argument that Mr. Hovind alone exercised dominion and control over CSE’s accounts, the preponderance of credible evidence in the record demonstrates, and we so find, that petitioner was actively involved in the operation of CSE and that she and Mr. Hovind jointly owned and operated CSE.
Respondent has introduced no credible evidence that petitioner was the sole owner of CSE or that Mr. Hovind had only minimal involvement in CSE’s operation. Accordingly, we are faced with the task of determining how much of CSE’s netprofit should be allocated to petitioner.[1]
Neither party introduced any definitive proof regarding a more precise allocation of income between petitioner and Mr. Hovind or credible evidence
regarding the scope of petitioner’s and Mr. Hovind’s involvement in CSE. In the absence of credible evidence regarding a more precise basis for allocating the net
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- ↑ We recognize respondent’s acknowledgment that he is seeking to tax CSE’s profits only once. Petitioner and Mr. Hovind, however, did not file joint returns for the years at issue, and therefore they are not jointly and severally liable for the determined income tax deficiencies.
