Robert John Kayian, Transferee - Page 8

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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-               
               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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