- 10 -
In addition to his discussions with Mr. Lanier about Mr.
Kayian, Sr.'s tax situation, Mr. Stephens performed an independ-
ent investigation to determine whether the information contained
in Mr. Kayian, Sr.'s Form 433-A was accurate and complete. As
part of Mr. Stephens' investigation of Mr. Kayian, Sr.'s finan-
cial situation, Mr. Stephens did not locate any assets owned by
Mr. Kayian, Sr. that were not shown in Mr. Kayian, Sr.'s Form
433-A. However, it would have been almost impossible for the
Service to discover offshore assets, such as the Aruba bonds.
On or about November 9, 1992, Mr. Stephens made handwritten
notations on Mr. Kayian, Sr.'s Form 433-A to update it, including
one notation which corrected a notation that Mr. Shatraw had made
on that form regarding ownership of one of the Key West con-
dominiums that Mr. Kayian, Sr. listed therein. After the updates
that Mr. Shatraw and Mr. Stephens made to Mr. Kayian, Sr.'s Form
433-A, that form indicated, inter alia, (1) that Mr. Kayian,
Sr.'s monthly expenses exceeded his monthly income by $588 and
(2) that the mortgage notes which Mr. Kayian, Sr. owned on
certain time-shares had a value of $60,000.
At some undisclosed time after Mr. Kayian, Sr. submitted to
the Service the returns for 1987 through 1991 that Mr. Lanier had
prepared, Mr. Lanier indicated to Mr. Kayian, Sr. that, in light
of the total amount of his 1987 through 1991 tax liability and
Mr. Lanier's understanding of Mr. Kayian, Sr.'s limited re-
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