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admitted under Rule 91(f). Petitioner resided in Los Angeles,
California, when her petition was filed in this Court.
Petitioner is a well-educated, intelligent, and highly
motivated individual. She is deeply involved in every aspect of
her business affairs and, as of 1992, had substantial experience
with business, finance, corporations, lawyers, and accountants.
She timely filed a 1996 joint Federal income tax return (1996
return) with her husband, John Bussell (Bussell). She married
Bussell in 1972, and they remained married until he took his own
life in 2002, near the completion of his and petitioner’s
criminal trial discussed infra.
Petitioner is a licensed physician and is board certified in
dermatology. She opened her dermatology practice (dermatology
practice) in March 1979, in Beverly Hills, California. In 1981,
she formed a wholly owned corporation, Letantia Bussell M.D.,
Inc., and that corporation operated the dermatology practice from
then until 1991. While the dermatology practice was operated by
Letantia Bussell M.D., Inc., petitioner received most if not all
of the net income generated by that practice as either wages or
distributions from the corporation.
II. Formation of Nominee Corporations
In 1991, petitioner instructed her attorneys, Jeffrey
Sherman (Sherman) and Robert Beaudry (Beaudry), to terminate
Letantia Bussell M.D., Inc., and in its stead to form a medical
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