Robert John Kayian, Transferee - Page 6

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          spectively.  On June 5, 1992, and July 7, 1992, respectively, Mr.           
          Kayian, Sr. and Ms. Livingston filed joint returns for 1990 and             
          1991 that Mr. Lanier had prepared for them.  Each of those                  
          returns showed tax due.  (We shall sometimes refer to the tax               
          liabilities, including applicable additions to tax and interest,            
          of Mr. Kayian, Sr. (1) for the years 1987 through 1989 as 1987              
          through 1989 tax liability and (2) for the years 1987 through               
          1991 as 1987 through 1991 tax liability.)                                   
               Mr. Kayian, Sr. did not pay his 1987 through 1991 tax                  
          liability when he filed returns for those years.  Consequently,             
          Mr. Shatraw turned his attention to the collection of that tax              
          liability.  In order to determine the financial ability of Mr.              
          Kayian, Sr. to pay his 1987 through 1991 tax liability, Mr.                 
          Shatraw asked Mr. Kayian, Sr. to complete and submit Form 433-A,            
          Collection Information Statement for Individuals.  The Service              
          uses Form 433-A to obtain financial information (e.g., income,              
          assets, and liabilities) regarding a taxpayer, on which the                 
          investigating revenue officer can rely in making a determination            
          about a taxpayer's ability to pay tax due.                                  
               On or about March 22, 1992, Mr. Kayian, Sr. submitted a                
          completed Form 433-A to Mr. Shatraw, which he signed under                  
          penalties of perjury (Mr. Kayian, Sr.'s Form 433-A).  Mr. Lanier            
          was not actively involved in the preparation or submission of               
          that form.  In Mr. Kayian, Sr.'s Form 433-A, Mr. Kayian, Sr.                

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