Letantia Bussell - Page 12

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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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