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          petitioner abruptly and drastically altered her corporate                   
          structure.  Her old professional corporation was scrapped and was           
          replaced by three nominee corporations in an arrangement which              
          even her tax attorney admitted, while testifying under oath,                
          illegally attempted to disguise petitioner’s earnings from the              
          provision of her medical services.  These corporations were                 
          formed with the express purpose of defrauding petitioner’s                  
          creditors, including respondent, and petitioner actively                    
          participated in this bankruptcy scheme, frequently asking                   
          specific questions as to it and making minute tactical decisions            
          regarding the concealment of her assets and income.  Petitioner             
          even boasted at one time that “I worked too damn hard for this              
          money to lose it to taxes”.                                                 
               Petitioner invites the Court to disregard the existence of             
          BBL and conclude that its $1,149,048 of income, which is all                
          attributable to 1993, 1994, and 1995, is, if at all, actually               
          taxable in those 3 nonnotice years.  We decline petitioner’s                
          invitation.  Petitioner purposely chose the corporate form and              
          actions of BBL, and she may not now argue against them.  See                
          Higgins v. Smith, 308 U.S. 473, 477 (1940).  Even if she could              
          challenge the existence of BBL in this proceeding, the record               
          before us convinces us that BBL was in fact a bona fide                     
          corporation.  BBL owned assets in its name, it held board                   
          meetings, and it employed the dermatology practice’s medical                
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