Robert John Kayian, Transferee - Page 18




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          that the Service would levy on his property in order to collect             
          that liability.  At the time Mr. Kayian, Sr. made the initial               
          transfer, he was bound to know that he had incurred substantial             
          medical expenses since he entered the hospital on August 6, 1993.           
               After Mr. Kayian, Sr. made the initial transfer, Mr. Kayian,           
          Jr., pursuant to Mr. Kayian, Sr.'s directions, (1) distributed              
          for no consideration and without an exchange of reasonably                  
          equivalent value a portion of the transferred properties valued             
          at $10,933.33 to (a) each of Mr. Kayian, Sr.'s remaining sons               
          (viz., petitioner Robert Kayian, Kenneth V. Kayian, and Richard             
          H. Kayian), (b) his daughter (viz., Karen Kayian Aubel), and                
          (c) two of his three grandchildren (viz., Kenneth J. Kayian-Beck            
          and Kaitlynn Elizabeth Kayian); (2) retained a portion of the               
          transferred properties valued at $16,400 and divided that portion           
          equally; and (3) distributed for no consideration and without an            
          exchange of reasonably equivalent value one-half of that retained           
          portion valued at $8,200 to Mr. Kayian, Sr.'s grandson (viz., Mr.           
          Kayian, Jr.'s son, petitioner Nicholaus Kayian).                            
               Although Ms. Livingston returned to Tampa on the day of Mr.            
          Kayian, Sr.'s funeral, she did not attend that funeral.  On that            
          day, Ms. Livingston withdrew all of the funds from the joint bank           
          accounts that she had with Mr. Kayian, Sr.  She previously had              
          taken Mr. Kayian, Sr.'s Rolex wristwatch with her when she left             







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