Letantia Bussell - Page 7

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          filed on June 25, 1993.  As of March 1995, petitioner’s unpaid              
          tax liabilities arising from that case had grown to approximately           
          $1 million, a sum which remained unpaid as of May 17, 2002.                 
          IV. The Bankruptcy Scheme                                                   
               The Bussells met with Sherman in 1991 to discuss the                   
          Bussells’ outstanding tax and nontax liabilities.  In late 1991             
          or early 1992, Sherman introduced the Bussells to Beaudry, and              
          the four of them met in petitioner’s livingroom and discussed               
          both the Bussells’ liabilities and aspects of petitioner’s                  
          finances.  During initial meetings with petitioner, Beaudry                 
          suggested a two-step scheme to defraud her creditors.  (In later            
          meetings with petitioner, as discussed infra, Beaudry expanded on           
          this suggestion as a method for petitioner also to accomplish her           
          objective of evading Federal income taxes on her income as well             
          as the income of entities that included at least BBL.)  Under the           
          first step, the Bussells would change title to their assets and             
          form nominee corporations; i.e., corporations that ostensibly               
          would be owned by someone other than the Bussells but which in              
          fact would be owned by one or both of the Bussells.  Those                  
          corporations would then realize the income earned by the                    
          dermatology practice in a fashion that would not allow that                 
          income to be attributed to petitioner.  Under the second step,              
          the Bussells would declare bankruptcy to discharge their                    
          creditors’ claims.  Beaudry finalized these suggestions in a                






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