- 39 - 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.Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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