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properties but not with respect to the interests of Mr. Kayian,
Jr. and his son Nicholaus Kayian with respect to those prop-
erties.
On November 2, 1995, Mr. Carr filed a notice of final
accounting and petition for discharge in the probate proceeding.
That notice showed that most of the distributions and disburse-
ments of Mr. Kayian, Sr.'s estate were made to pay Ms. Livingston
a family allowance as well as fees as personal representative of
Mr. Kayian, Sr.'s estate, attorney's fees, accounting fees, and
other costs and expenses. On December 5, 1995, the Probate Court
issued an order in the probate proceeding discharging Ms.
Livingston as the personal representative of Mr. Kayian, Sr.'s
estate.
Respondent issued separate notices of transferee liability
to petitioner Robert Kayian and petitioner Nicholaus Kayian,
respectively, in which respondent determined that they are liable
as transferees in amounts not exceeding $10,933 and $8,200,
respectively, plus interest thereon as provided by law, for Mr.
Kayian, Sr.'s 1987-1989 unpaid tax liability.
OPINION
We shall first address certain evidentiary matters. At
trial, we admitted into evidence conditionally, subject to our
ruling on admissibility, certain evidence to which respondent
objected.
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