Robert John Kayian, Transferee - Page 13




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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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