Robert John Kayian, Transferee - Page 10

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               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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