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(Ghassemi), an employee and bookkeeper of the dermatology
practice since 1983, as BBL’s apparent owner, president, and
chief executive officer (CEO). Ghassemi signed BBL’s
incorporation documents at the request of petitioner and Bussell
(collectively, the Bussells) but had no duties or
responsibilities as BBL’s owner, president, or CEO. Ghassemi’s
sole function was to sign blank checks drawn on a BBL account
when they were presented to her by either of the Bussells.
(Bussell was BBL’s president and secretary.) In August 1995, BBL
was replaced as the operator of the dermatology practice by a
fourth corporation, Beverly Hills Management, Inc., but BBL was
neither terminated nor liquidated at that time. On November 15,
1995, BBL’s board of directors met and adopted a resolution
authorizing Bussell to open for BBL a bank account with Paine
Webber (the Paine Webber account, described infra). On
January 16, 1996, Bussell opened up the Paine account in the name
of BBL.
Petitioner formed the second of the three corporations,
Beverly Hills Dermatology Medical Corp. (BHDMC), in California in
February 1993. Beaudry advised petitioner that BHDMC should be
owned by a third-party doctor, and petitioner asked her friend
Marilyn Lange, M.D. (Lange), to assist her with respect to BHDMC.
At petitioner’s request, Lange served as BHDMC’s apparent, but
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