- 5 - 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-Page: 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