- 4 - which included accrued interest, was as high as $99,000. Around August 1992, Mr. Kayian, Sr. began receiving monthly payments with respect to the Aruba bonds. Mr. Kayian, Sr. and Ms. Livingston did not file any tax returns (returns) while they were living in Aruba. As of January 1992, Mr. Kayian, Sr. had not filed returns for taxable years 1986 through 1990. Nor had he made any estimated tax payments during 1985 through 1990 or thereafter during 1991 and 1992. Because the Service's records showed that substantial amounts of income had been reported to the Service as having been paid to Mr. Kayian, Sr. during 1987 through 1989 and that Mr. Kayian, Sr. should have filed returns for those years, revenue officer John Shatraw (Mr. Shatraw) of the Service's collection division was assigned to investigate and to issue a summons with respect to those delinquent returns. In early February 1992, Mr. Shatraw served a summons (summons) on Mr. Kayian, Sr. to compel him to produce the books and records necessary to prepare and file his returns for 1987 through 1989. Mr. Kayian, Sr. had not filed his returns for 1987, 1988, and 1989 prior to February 26, 1992, when he and Mr. Kayian, Jr. met with Mr. Shatraw about the summons (February 26, 1992 meet- ing). Nor did he bring those returns to that meeting. Mr. Kayian, Sr. disclosed to Mr. Shatraw at the February 26, 1992 meeting that he had throat cancer and requested additional timePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011