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Nancy Kayian (Ms. Livingston), and they were married in 1990.
Mr. Kayian, Jr. did not like Ms. Livingston, who was only a few
years older than he was, and was suspicious of her intentions in
marrying his father. After Mr. Kayian, Sr. married Ms.
Livingston, the relationship of Mr. Kayian, Jr. with his father
changed in that, inter alia, Mr. Kayian, Jr. never had the
opportunity to be alone with him.
From sometime in 1990 until mid-March 1991, Mr. Kayian, Sr.
and Ms. Livingston lived in Aruba in housing provided by a resort
for which Mr. Kayian, Sr. was selling time-shares. In mid-March
1991, Mr. Kayian, Sr. and Ms. Livingston moved from Aruba to Key
West, Florida (Key West), where they lived until July of that
year. In July 1991, they moved from Key West to Tampa, Florida
(Tampa), where they purchased a residence. Mr. Kayian, Sr. had
the title of that Tampa residence placed solely in the name of
Ms. Livingston in an attempt to preclude the Internal Revenue
Service (the Service) from using it in order to satisfy any
outstanding tax liability that he had.
Sometime while Mr. Kayian, Sr. and Ms. Livingston were
living in Aruba, Mr. Kayian, Sr. acquired bearer bonds issued by
Natex Investments A.V.V. (Aruba bonds). After they returned to
the United States, Mr. Kayian, Sr. and Ms. Livingston received
statements with respect to those bonds on a regular basis.
During 1992 and 1993, the balance shown on those statements,
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