- 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 time
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