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Kayian, Sr.'s Form 433-A, although he attempted to verify the
accuracy and completeness of that form and made a few notations
on that form based principally on his discussions with Mr.
Kayian, Sr. Since certain assets that Mr. Kayian, Sr. listed in
that form were located in the vicinity of Miami, Florida (Miami),
Mr. Shatraw contacted the Miami office of the Service's col-
lection division for assistance in verifying Mr. Kayian, Sr.'s
Form 433-A. However, that office was unable to provide any
assistance to Mr. Shatraw because its operations were temporarily
affected due to Hurricane Andrew.
Mr. Kayian, Sr. never disclosed to Mr. Shatraw or other
personnel of the Service that he owned the Aruba bonds, and it
would have been almost impossible for the Service to discover
such an offshore asset. If Mr. Kayian, Sr. had informed Mr.
Shatraw about those Aruba bonds, Mr. Shatraw would have required
Mr. Kayian, Sr. to liquidate those bonds and apply the bond
proceeds toward satisfaction of his 1987 through 1989 tax li-
ability.
Mr. Kayian, Sr. consistently represented to Mr. Shatraw that
he intended to pay in full his 1987 through 1989 tax liability.
Between April 13, 1992, and August 5, 1992, Mr. Kayian, Sr. made
payments to the Service totaling approximately $16,735 that the
Service credited to his tax liability for 1987. Mr. Kayian, Sr.
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