- 6 -
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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