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for the Syntex account, but he had no duties or responsibilities
in that capacity, and he never signed any documents authorizing
the transfer of funds from that account. The Bussells (and not
Syntex) were the actual owners of the Syntex account, and they
exercised control over the account.
In 1993, at Bussell’s request, Beaudry transferred funds
from Bussell’s pension plan into the Syntex account. Petitioner
was aware of this transfer, and before (but in connection with)
this transfer she was advised by Beaudry that the transfer was a
premature distribution from a pension plan, that it was required
to be reported as such on her joint 1993 Federal income tax
return (1993 return), and that the failure to report it as such
was a crime. The Bussells did not report this transfer on the
1993 return.
During 1996, the Bussells maintained another, personal bank
account at Swiss Bank Corp. (personal Swiss bank account). The
Bussells failed to report the personal Swiss bank account on
their 1996 return. They also failed to report the Syntex account
on their personal Federal income tax returns for 1993, 1994,
1995, and 1996.
Petitioner used multiple post office boxes in an attempt to
conceal her ownership of BBL and BHDMC, as well as her
relationship with other entities and financial accounts. During
the relevant years, the Bussells opened at least eight personal
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