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The tax evasion count for 1983, 1984, 1986, and 1987 alleged in
relevant part that the Bussells attempted to evade the payment of
$353,394 of Federal income taxes for those years by knowingly and
fraudulently concealing their assets inclusive of their
beneficial ownership interests in BBL and BHDMC. The tax evasion
count for 1996 alleged that petitioner operated the dermatology
practice through a three-tier structure, including BBL; that the
Bussells effectively managed and controlled BBL through nominee
owners; that the Bussells failed to report the $1,149,048 at
issue as income on the 1996 return; and that the Bussells had
1996 tax due and owing to the United States.
The Bussells’ criminal trial began on November 20, 2001, and
ended on February 6, 2002. The trial resulted in petitioner’s
conviction of five of the counts related to bankruptcy fraud and
the single count under section 7201 related to the attempted
evasion of $353,394 of Federal income taxes for 1983, 1984, 1986,
and 1987. Petitioner’s convictions are currently on appeal.
X. Petitioner’s Failure To Cooperate With the Court
Rule 91(a) requires that all parties stipulate all facts and
documents to the fullest extent possible. On November 18, 2003,
the Court reiterated the importance of this Rule when we ordered
the parties to stipulate to the greatest extent possible. On or
about November 26, 2003, respondent sent petitioner a proposed
stipulation of facts with exhibits (stipulation). Petitioner
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