Robert John Kayian, Transferee - Page 9

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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.              

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