Robert John Kayian, Transferee - Page 7

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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            

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