Robert John Kayian, Transferee - Page 14

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          existence of the Aruba bonds, he would not have made that rec-              
          ommendation.  Instead, he would have requested that Mr. Kayian,             
          Sr. liquidate those bonds and use the bond proceeds toward                  
          satisfaction of his outstanding tax liability.  Mr. Stephens'               
          supervisor rejected Mr. Stephens' recommendation that the Service           
          accept the 1987 through 1989 amended offer and the 1990-1991                
          amended offer.                                                              
               In a letter dated December 21, 1992, Mr. Lanier wrote to Mr.           
          Stephens concerning a proposed examination of Mr. Kayian, Sr.'s             
          returns for 1988 and 1989.  That letter stated:  "It just seems             
          pointless to go through with the examination because there are no           
          more assets available to pay any additional taxes."  On June 8,             
          1993, Mr. Kayian, Sr. withdrew the 1987 through 1989 amended                
          offer and the 1990-1991 amended offer.                                      
               Mr. Kayian, Sr. executed under oath a financial affidavit              
          dated March 18, 1993 (financial affidavit), with respect to a               
          lawsuit that his former spouse Beatrice Kayian (Beatrice Kayian             
          lawsuit) commenced against him in the family law division of the            
          Circuit Court of the 13th Judicial Circuit in and for Hills-                
          borough County, Florida (13th Circuit Court).  In that affidavit,           
          Mr. Kayian, Sr. represented, inter alia, (1) that he had monthly            
          expenses of $2,680 which exceeded his monthly income of $2,200,             
          (2) that the aggregate value of the mortgage notes that he owned            

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