Letantia Bussell - Page 14

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          transferred $820,000, from the Syntex account to the personal               
          Swiss bank account.                                                         
               On May 31, 1996, Beaudry made a second wire transfer, of               
          $331,616, from the CITCO account to the Medifor account.  Beaudry           
          then transferred $309,010 from the Medifor account to the Syntex            
          account.  On or about June 11, 1996, Bussell transferred $309,010           
          from the Syntex account to the personal Swiss bank account.                 
          Approximately 1 month after the second transfer, the Bussells               
          made another trip to Zurich, Switzerland.                                   
               After these transfers into the Syntex account took place,              
          Kusch was notified by Swiss Bank Corp. about the transfers.  He             
          then went to Swiss Bank Corp. on October 21, 1996, and formally             
          resigned as the Syntex account’s investment advisor.                        
          VIII.  Failure To File Tax Returns                                          
               For most of the relevant years, the accounting and                     
          bookkeeping services for the Bussells and BBL were performed by             
          Steve Berson (Berson).  Berson knew that BBL was profitable and             
          was required to file Federal income tax returns for 1992, 1993,             
          1994, and 1995.  Berson prepared a draft 1993 Federal income tax            
          return for BBL that reported a tax liability.  Bussell directed             
          Berson not to finalize or file that return.  Berson notified                
          petitioner of this decision and the fact that BBL was in a                  
          delinquent filing status.  Petitioner did not want to pay any tax           
          on BBL’s income, and Berson was instructed to file false Federal            






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