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obtained approximately $13,000 of those payments by liquidating
certain assets listed in Mr. Kayian, Sr.'s Form 433-A.
On July 20, 1992, due to the failure of Mr. Kayian, Sr. to
pay in full his 1987 through 1989 tax liability, the Service
recorded a notice of Federal tax lien in an amount totaling
$68,243.27 in Hillsborough County, Florida. Mr. Kayian, Sr. made
no further payments of his outstanding tax liability after August
5, 1992.
At some time between July 20, 1992, and September 4, 1992,
the collection of Mr. Kayian, Sr.'s 1987 through 1991 tax li-
ability was transferred to revenue officer Claude A. Stephens
(Mr. Stephens). On September 4, 1992, Mr. Stephens sent Mr.
Kayian, Sr. a final notice of intention to levy with respect to
the respective taxes that were shown due in the 1990 and 1991
joint returns that Mr. Kayian, Sr. and Ms. Livingston had sub-
mitted to the Service.
Through at least November 9, 1992, Mr. Stephens communicated
with Mr. Lanier with respect to, inter alia, the assets and
liabilities listed in Mr. Kayian, Sr.'s Form 433-A. The in-
formation that Mr. Lanier provided to Mr. Stephens during those
communications was based solely on information that Mr. Lanier
had obtained from Mr. Kayian, Sr. Mr. Stephens was never made
aware of the existence of the Aruba bonds that Mr. Kayian, Sr.
owned.
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