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1988, 1989, 1990, and 1991." Mr. Stephens reviewed the foregoing
amended offers-in-compromise. Based on the value of all of the
assets disclosed in Mr. Kayian, Sr.'s Form 433-A, discussions
with Mr. Kayian, Sr. and Mr. Lanier, and Mr. Stephens' independ-
ent investigation of Mr. Kayian, Sr.'s financial situation, Mr.
Stephens prepared what the Service refers to as a reasonable
collection potential computation. Such a computation is used to
ascertain the reasonable collection potential of a taxpayer who
has submitted an offer-in-compromise to the Service. In pre-
paring that reasonable collection potential computation with
respect to Mr. Kayian, Sr., Mr. Stephens did not include the
value of the Aruba bonds or any other assets or interests which
Mr. Kayian, Sr. owned but which were not disclosed in Mr. Kayian,
Sr.'s Form 433-A or in discussions with Mr. Kayian, Sr. and Mr.
Lanier.
Based on the information provided by Mr. Kayian, Sr. and Mr.
Lanier, Mr. Stephens concluded that there existed a doubt as to
the collectability of Mr. Kayian, Sr.'s 1987 through 1989 tax
liability and Mr. Kayian, Sr. and Ms. Livingston's joint 1990 and
1991 tax liability and that an acceptable offer-in-compromise of
Mr. Kayian, Sr.'s 1987 through 1991 tax liability was $23,121.40.
On December 11, 1992, Mr. Stephens recommended to his supervisor
that the Service accept the 1987 through 1989 amended offer and
the 1990-1991 amended offer. If Mr. Stephens had known of the
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