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sources, Mr. Kayian, Sr. should consider submitting offers-in-
compromise with respect to that tax liability. Because Mr.
Kayian, Sr. was not familiar with an offer-in-compromise, Mr.
Lanier explained to him what such an offer is. In recommending
to Mr. Kayian, Sr. that he consider submitting an offer-in-
compromise and in preparing separate offers-in-compromise with
respect to Mr. Kayian, Sr.'s 1987 through 1989 tax liability and
Mr. Kayian, Sr. and Ms. Livingston's joint tax liability for 1990
and 1991 (joint 1990 and 1991 tax liability), Mr. Lanier relied
on the information provided to him by Mr. Kayian, Sr. about his
assets and did not independently verify that information. At no
point did Mr. Kayian, Sr. divulge to Mr. Lanier that he owned the
Aruba bonds or any other bonds. If Mr. Kayian, Sr. had informed
Mr. Lanier about the Aruba bonds, Mr. Lanier would have disclosed
that information to the Service, and it would have impacted Mr.
Lanier's preparation of offers-in-compromise for Mr. Kayian, Sr.
On December 7, 1992, Mr. Kayian, Sr. signed, under penalties
of perjury, an amended offer-in-compromise that Mr. Lanier had
prepared, in which he offered to satisfy for $23,121.40 his 1987
through 1989 tax liability (1987 through 1989 amended offer),
which totaled $72,807.59. On the same date, Mr. Kayian, Sr. and
Ms. Livingston signed, under penalties of perjury, an amended
offer-in-compromise that Mr. Lanier had prepared, in which they
offered to satisfy for the same $23,121.40 their joint 1990 and
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