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written analysis of petitioner’s assets and liabilities,
concluding with a series of recommendations. Petitioner asked
specific questions as to the bankruptcy scheme, e.g., who would
be involved in it, what would it cost, and what were the
advantages and disadvantages of certain decisions, and she
expressly approved the bankruptcy scheme’s purpose of defrauding
creditors. Petitioner was an active participant in formulating
most, if not all, of the details of the bankruptcy scheme.
After petitioner approved the bankruptcy scheme, Beaudry
usually met with Bussell regarding the scheme’s administrative
details. Beaudry would contact petitioner the day of the
meeting, or soon thereafter, to inform her of the matter that had
been addressed and to confirm that she agreed with the decisions
made. All of the decisions made regarding the dermatology
practice were expressly approved by petitioner, and only
recommendations approved by petitioner were implemented.
V. Concealment of Assets
On May 26, 1993, with the consent of petitioner, Beaudry
formed a shell corporation, Syntex Financial Corp. (Syntex), in
the British Virgin Islands. Also around that time, the Bussells
traveled to Zurich, Switzerland, with a personal friend, a German
citizen named Gerd Kusch (Kusch). There, they opened a bank
account at Swiss Bank Corp. in the name of Syntex (Syntex
account). Kusch was named in form as the “investment advisor”
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