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ceeding $10,933 and $8,200, respectively, plus interest thereon
as provided by law, for the unpaid Federal income tax (tax)
liability of Harry K. Kayian, Sr. (Mr. Kayian, Sr.) for 1987,
1988, and 1989 in the amounts of $1,503, $18,959, and $26,442,
respectively, plus interest thereon as provided by law (Mr.
Kayian, Sr.'s 1987-1989 unpaid tax liability).1 We must decide
whether those determinations should be sustained. We hold that
they should.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time Robert Kayian filed his petition in this case,
he resided in Brandon, Florida. At the time Nicholaus Kayian
filed his petition in this case, he resided in Tampa, Florida.
Mr. Kayian, Sr., who died intestate on August 17, 1993,
after a long illness, was the father of petitioner Robert Kayian,
Harry Kayian, Jr. (Mr. Kayian, Jr.), Kenneth V. Kayian, Richard
H. Kayian, and Karen Kayian Aubel and the grandfather of pe-
titioner Nicholaus Kayian, Kenneth J. Kayian-Beck, and Kaitlynn
E. Kayian. Mr. Kayian, Jr. is the father of Nicholaus Kayian.
In September 1989, Mr. Kayian, Sr., who had been married to
Beatrice L. Kayian (Beatrice Kayian), met Nancy Livingston f/k/a
1Unless otherwise indicated, all section references are to
the Internal Revenue Code (Code) in effect for the years at
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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