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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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