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indicated, inter alia, (1) that he maintained an IRA with Jackson
National Insurance Company (Jackson National),2 but he did not
indicate the balance in that account; (2) that he owned two
condominium units in Key West (Key West condominiums), in which
he had equity totaling $42,775; (3) that he did not own any life
insurance policies; (4) that he owned mortgage notes receivable
worth $120,000 on certain time-share units (time-shares);
(5) that he anticipated an increase in his income; (6) that he
was involved in court proceedings regarding alimony; (7) that he
had owned another condominium unit in Key West which had been re-
possessed; and (8) that he had not made any recent transfers of
assets for less than full value. Mr. Kayian, Sr. did not dis-
close the Aruba bonds in the Form 433-A that he completed and
submitted to Mr. Shatraw. Nor did he disclose in that form that
he maintained with Continental Life & Accident Company (Con-
tinental) an annuity contract (Continental annuity contract) and
a separate group life insurance policy (Continental group life
insurance policy).
In determining the potential to collect Mr. Kayian, Sr.'s
1987 through 1991 tax liability, Mr. Shatraw relied on Mr.
2Although not altogether clear from the record, it appears
that the IRA with Jackson National to which Mr. Kayian, Sr. was
referring consisted of an annuity contract that he had purchased
from Jackson National on Apr. 15, 1988 (Jackson National annuity
contract).
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