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not actual, owner and director. The Bussells gave BHDMC’s
incorporation documents to Lange, and she signed them. Lange had
no involvement in the daily operations of BHDMC and opened no
corporate bank accounts for BHDMC. Lange’s name was used as the
signatory on a BHDMC bank account, and her name was signed on
checks drawn from this account without either her actual
signature or her consent to the signing of her name. Lange had
no involvement in the banking of BHDMC, and she did not have any
financial interest in BHDMC.
The third of the three corporations was LB Bussell Medical
Corp. (LBB), incorporated in California in June 1992. From 1993
to 1996, petitioner was identified as an employee of LBB, and it
paid her all of the wages that she received during those years.
At the beginning of 1994, petitioner became the sole shareholder
of LBB in form as well as in substance.
III. Petitioner’s Tax Liabilities
In 1991, petitioner received notice from respondent that she
potentially owed $1.2 million in Federal income taxes for 1983,
1984, 1986, and 1987. Petitioner met with Sherman to discuss
these taxes sometime before December 20, 1991, when respondent
issued to her a notice of deficiency for those 4 years.
Petitioner, represented by Sherman, petitioned this Court as to
that notice of deficiency. The resulting case, docket No.
6156-92, was ultimately settled pursuant to a stipulated decision
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