- 11 - 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 andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011