Letantia Bussell - Page 33

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               8.  Attempting To Conceal Illegal Activities                           
               Attempting to conceal illegal activities is indicative of              
          fraud.  Id.                                                                 
               Petitioner went to great lengths to conceal her illegal                
          activities.  Those efforts included taking part in the bankruptcy           
          scheme, concealing her beneficial ownership in certain entities             
          connected therewith, and using offshore bank accounts.                      
               This factor weighs against petitioner.                                 
               9.  Other Considerations                                               
               Petitioner is well educated and intelligent.  She also is              
          deeply involved in every aspect of her business affairs and has             
          substantial experience with business, finance, corporations,                
          lawyers, and accountants.                                                   
               10. Conclusion                                                         
               Our analysis above concludes that seven of the eight factors           
          weigh against petitioner and that the remaining factor is                   
          neutral.  On the basis of our detailed review of the facts and              
          circumstances of this case, in conjunction with our analysis of             
          the eight factors mentioned above and our “other considerations”,           
          we conclude that respondent has clearly and convincingly proven             
          that petitioner filed her 1996 return intending to conceal,                 
          mislead, or otherwise prevent the collection of tax.                        









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