Page:T.C. Memo. 2012-281.pdf/6

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[*6] 

III. Expansion of CSE: 1999-2002

From 1999 through 2002 CSE expanded its operations by purchasing properties surrounding the 29 Cummings Road property. In October 1999 Mr. Hovind signed a warranty deed for property at 21-23 Cummings Road (21-23 Cummings Road property).[1] In March 2000 Mr. Hovind acquired property at 400 Cummings Road (400 Cummings Road property). In May 2001 petitioner and Mr. Hovind purchased property at 5720 North Palafox (5720 North Palafox property) from Darlene Porter.[2] In September 2001 petitioner and Mr. Hovind purchased property at 5800 North Palafox (5800 North Palafox property) from Delores Choron.[3]


  1. Petitioner drafted and signed two checks drawn on a CSE account to pay for the property.
  2. The settlement statement for the 5720 North Palafox property recites that petitioner and Mr. Hovind were to pay $126,391 for the property. To pay for the property, CSE gave AmSouth two checks drawn on CSE accounts totaling $126,391 in exchange for an official bank check in the same amount. Petitioner drafted and signed the two checks drawn on the CSE accounts. Petitioner and Mr. Hovind also purchased personal property from Ms. Porter. As partial payment for Ms. Porter's personal property, CSE gave AmSouth a check drawn on a CSE account in exchange for four official bank checks totaling $30,000. Petitioner drafted and signed the check drawn on a CSE account. She also drafted and signed a check drawn on a CSE account made payable to Ms. Porter.
  3. During 2002-03 petitioner drafted and signed 11 checks drawn on a CSE account made payable to Ms. Choron.