Robert John Kayian, Transferee - Page 5

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          within which to prepare and file his returns for 1987, 1988, and            
          1989.  Mr. Shatraw granted Mr. Kayian, Sr.'s request.                       
               Mr. Kayian, Jr. recommended to Mr. Kayian, Sr. that he                 
          retain a return preparer to assist him in the preparation of his            
          delinquent returns.  Mr. Kayian, Jr. referred Mr. Kayian, Sr. to            
          Ashley Lanier (Mr. Lanier), a certified public accountant since             
          1960 who had extensive experience in the preparation of returns             
          and whom Mr. Kayian, Jr. was using as his return preparer.  Mr.             
          Kayian, Sr. retained Mr. Lanier and met with him on several                 
          occasions as part of Mr. Lanier's efforts to obtain from Mr.                
          Kayian, Sr. information, including information about any interest           
          and other income that Mr. Kayian, Sr. received, that Mr. Lanier             
          needed in order to prepare Mr. Kayian, Sr.'s returns for 1987,              
          1988, and 1989 and joint returns of Mr. Kayian, Sr. and Ms.                 
          Livingston for 1990 and 1991.  Mr. Kayian, Jr. was present at two           
          of those meetings.  Mr. Kayian, Sr. never disclosed to Mr. Lanier           
          that he owned the Aruba bonds or that he received interest income           
          from those or any other bonds.                                              
               On March 2, 1992, March 30, 1992, and April 13, 1992,                  
          respectively, Mr. Kayian, Sr. filed the returns for 1987, 1988,             
          and 1989 that Mr. Lanier had prepared for him.  Each of those               
          returns showed that tax was due.  Respondent assessed the tax               
          shown due in those returns, plus applicable additions to tax and            
          interest, on May 4, 1992, May 18, 1992, and June 1, 1992, re-               

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