- 13 - 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 thePage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011