Letantia Bussell - Page 9

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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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