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of his Continental annuity contract to his grandsons Nicholaus
Kayian and Kenneth John Kayian-Beck and his granddaughter
Kaitlynn Elizabeth Kayian. Mr. Kayian, Sr.'s Continental annuity
contract had a cash surrender value of at least $14,000 and was
to pay interest from date of death. By letter dated August 16,
1993, which he did not sign, Mr. Kayian, Sr. requested Jackson
National to change the beneficiary of his Jackson National
annuity contract to his grandsons Nicholaus Kayian and Kenneth
John Kayian-Beck and his granddaughter, Kaitlynn Elizabeth
Kayian. Mr. Kayian, Sr.'s Jackson National annuity contract had
an accumulation value and death benefit of $59,262.39. Mr.
Kayian, Jr. and Robert Kayian signed each of the foregoing
letters as witnesses.
Also on or about August 16, 1993, Mr. Kayian, Sr. trans-
ferred to Mr. Kayian, Jr. (initial transfer) the Aruba bonds
valued at $70,000 and the Social Security check for $12,000
(collectively, transferred properties) and directed him to
distribute the transferred properties to Mr. Kayian, Sr.'s
children and grandchildren (Mr. Kayian, Sr.'s directions). Mr.
Kayian, Sr. made the initial transfer for no consideration and
without an exchange of reasonably equivalent value. When Mr.
Kayian, Sr. made the initial transfer, he was well aware, and Mr.
Kayian, Jr. was aware generally, of Mr. Kayian, Sr.'s 1987
through 1991 tax liability, and Mr. Kayian, Sr. was bound to know
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