Robert John Kayian, Transferee - Page 4

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          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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