Robert John Kayian, Transferee - Page 11




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          sources, Mr. Kayian, Sr. should consider submitting offers-in-              
          compromise with respect to that tax liability.  Because Mr.                 
          Kayian, Sr. was not familiar with an offer-in-compromise, Mr.               
          Lanier explained to him what such an offer is.  In recommending             
          to Mr. Kayian, Sr. that he consider submitting an offer-in-                 
          compromise and in preparing separate offers-in-compromise with              
          respect to Mr. Kayian, Sr.'s 1987 through 1989 tax liability and            
          Mr. Kayian, Sr. and Ms. Livingston's joint tax liability for 1990           
          and 1991 (joint 1990 and 1991 tax liability), Mr. Lanier relied             
          on the information provided to him by Mr. Kayian, Sr. about his             
          assets and did not independently verify that information.  At no            
          point did Mr. Kayian, Sr. divulge to Mr. Lanier that he owned the           
          Aruba bonds or any other bonds.  If Mr. Kayian, Sr. had informed            
          Mr. Lanier about the Aruba bonds, Mr. Lanier would have disclosed           
          that information to the Service, and it would have impacted Mr.             
          Lanier's preparation of offers-in-compromise for Mr. Kayian, Sr.            
               On December 7, 1992, Mr. Kayian, Sr. signed, under penalties           
          of perjury, an amended offer-in-compromise that Mr. Lanier had              
          prepared, in which he offered to satisfy for $23,121.40 his 1987            
          through 1989 tax liability (1987 through 1989 amended offer),               
          which totaled $72,807.59.  On the same date, Mr. Kayian, Sr. and            
          Ms. Livingston signed, under penalties of perjury, an amended               
          offer-in-compromise that Mr. Lanier had prepared, in which they             
          offered to satisfy for the same $23,121.40 their joint 1990 and             





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