report) before PDC issued any checks to them. Residents at several of the entities' listed business addresses also testified that no drywall businesses operated from the listed addresses. In addition, two foremen who worked for PDC during the relevant time said they had not seen subcontractors at job sites during their tenure and that they were not aware of the existence of the six subcontractors. The foremen also testified that drywall work was seasonal, with less work in the winter. IRS Special Agent Helene Seltzer testified that the hundreds of checks made out from PDC to the six subcontractors showed no seasonal fluctuation. The jury also heard that Presbitero ordered blank invoice forms for invoices from the six subcontractors and asked that each invoice look "different." The formscompany delivered the blank invoices not to any subcontractors, but to PDC.
Velasquez was in charge of hiring, managing, and assigning PDC's drywall installers. Each week, for several years, Velasquez and others told Presbitero's assistant the number of hours subcontractors had purportedly worked that week. The assistant then prepared checks and gave them to Presbitero, who signed them. She also prepared invoices from the six subcontractors to PDC, but the invoices were never mailed anywhere. Nor did she recall ever receiving a piece of mail, telephone call, or visit from a subcontractor.
Instead of mailing checks to the subcontractors, Velasquez or his sister, father, or one of his children would pick up the checks from Presbitero's assistant. Velasquez had made arrangements with Leonard Sklare whereby Sklare agreed to cash the