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bank accounts, using false Social Security numbers to conceal
their identities.
VI. Concealment of Income
Pursuant to the bankruptcy scheme, petitioner caused
approximately $1,149,048 of income earned by the dermatology
practice from 1993, 1994, and 1995 to be accumulated in a BBL
account at Sanwa Bank (Sanwa account), and she did not cause any
of those funds (with the exception of a check in payment of a
$51.96 check printing fee) to be withdrawn from that account
until January 1996, after her bankruptcy case was discharged. In
January 1996, she caused the balance of the Sanwa account
($1,149,048) to be transferred to the personal Swiss bank
account.
Petitioner caused the Sanwa account to be opened on May 14,
1993, as a non-interest-bearing account to hide further the
existence of the account, and it was opened using the names of
Kusch and petitioner’s patient Josephine Isaacs (Isaacs) as
signatories in order to hide further petitioner’s actual
ownership interest in the Sanwa account. Neither Kusch nor
Isaacs signed the bank’s signature card, and neither Kusch nor
Isaacs authorized another individual to sign for him or her. The
Bussells retained possession and control of the checkbooks and
bank statements for the Sanwa account.
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