Robert John Kayian, Transferee - Page 39

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          1992 when the Service was attempting to collect Mr. Kayian, Sr.'s           
          1987-1989 unpaid tax liability as well as Mr. Kayian, Sr. and Ms.           
          Livingston's joint 1990 and 1991 tax liability.6  Mr. Kayian, Sr.           
          thus concealed assets from the Service.7  See Fla. Stat. Ann.               
          sec. 726.105(2)(g).  (3) Although Mr. Kayian, Sr.'s liability for           
          tax due for each of the years 1987 through 1989 arose on the date           
          on which his return for each such year was required to be filed,            
          Mr. Kayian, Sr.'s tax liability for each of those years was not             
          quantified until after the Service summoned him in early February           
          1992 with respect to his taxable years 1987 through 1989 and he             
          prepared and submitted to the Service returns for those years on            
          March 2, 1992, March 30, 1992, and April 13, 1992, respectively.            
          Those returns showed taxes due, and respondent assessed those               
          taxes, plus applicable additions to tax and interest, on May 4,             
          1992, May 18, 1992, and June 1, 1992, respectively.  In addition,           
          on June 5, 1992, and July 7, 1992, respectively, Mr. Kayian, Sr.            
          and Ms. Livingston submitted to the Service joint returns for               
          1990 and 1991, which showed taxes due.  When Mr. Kayian, Sr. gave           
          the transferred properties to Mr. Kayian, Jr., he was well aware            

               6On the record before us, we reject petitioner's contention            
          that Mr. Kayian, Sr. did not disclose the Aruba bonds to the                
          Service because he thought those bonds were worthless.                      
               7It is also noteworthy that in answers to interrogatories              
          and in a financial affidavit, both of which he prepared with                
          respect to the Beatrice Kayian lawsuit, Mr. Kayian, Sr. did not             
          disclose that he owned the Aruba bonds.                                     

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