What is the test for wilful misappropriation of funds from an attorney's trust account?

Petitioner does not deny that on numerous occasions his trust account was either overdrawn or the balance fell far below the amount he should have had on account. Nor does he dispute that he refused to make payments to the heirs of various [591 P.2d 50] estates when they were due. Evidence that petitioner persistently refused to account to the heirs in the face of repeated demands to do so justifies a finding of wilful misappropriation. (Brody v. State Bar (1974) 11 Cal.3d 347, 350, 113 Cal.Rptr. 371, 521 P.2d 107.) Even if petitioner's misconduct were not wilful and dishonest, gross carelessness and negligence constitute a violation of an attorney's oath faithfully to discharge his duties and involve moral turpitude. (Doyle v. State Bar (1976)15 Cal.3d 973, 978, 126 Cal.Rptr. 801, 544 P.2d 937.)