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

[*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.

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, 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 ___________