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over $1 million was Federal taxes owed to respondent. In August
1995, petitioner was granted a discharge, and her bankruptcy case
was closed.
Before January 1, 1996, no withdrawals or transfers were
made from, and no checks were drawn on, the Sanwa account, except
for a $51.96 check written for check printing fees. On or about
December 21, 1995, petitioner met with Beaudry and Sherman to
discuss a plan to transfer the full balance of the Sanwa account,
all of which was attributable to BBL’s operation of the
dermatology practice, from the Sanwa account to her personal
account by way of a series of offshore accounts to conceal the
transfer.
In January 1996, Bussell forged Kusch’s signature without
his permission on a single $1,149,048 check drawn on the Sanwa
account and made payable to Paine Webber, leaving the Sanwa
account with a zero balance. This check was deposited into the
Paine Webber account. The Paine Webber account was a brokerage
account maintained by a New York, New York, office of Paine
Webber. Bussell opened the Paine Webber account in the name of
BBL on January 16, 1996, and petitioner signed as a witness on
documents used to open the account.
Bussell, in his capacity as an officer of BBL, was the only
person authorized to withdraw funds from the Paine Webber
account. Within 1 month of its creation, all funds in the Paine
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