- 7 - 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 aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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