- 24 - 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 medicalPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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