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States Estate Tax Return, naming as coexecutrixes Ms. Norquist at
962 Stage Road, Aspen, Colorado 81611 (the Aspen address), and
Mrs. Stamey at the Wroxton Road address. The estate attached to
the estate tax return a Form 2848, Power of Attorney, dated
May 25, 1999, which also provided the Aspen address for Ms.
Norquist3 and the Wroxton Road address for Mrs. Stamey. The
power of attorney directed that respondent send all original
notices or communications to Anne Hardiman (Ms. Hardiman), the
attorney who prepared the estate tax return.
The estate filed Form 1041, United States Income Tax Return
for Estates and Trusts, for each of the taxable years 1998 and
1999. Both the 1998 return, filed on or about January 27, 2000,
and the 1999 return, filed on or about January 22, 2001, listed
the Wroxton Road address as the address for the estate, Ms.
Norquist, and Mrs. Stamey.
On November 19, 2001, the estate mailed to respondent a new
Form 2848 that revoked the prior power of attorney, directed that
the estate receive all original notices and communications, and
listed the Wroxton Road address as the mailing address for the
estate, Ms. Norquist, and Mrs. Stamey. The power of attorney
also required that respondent send a copy of all notices and
communications to the estate’s attorney, Edward D. Urquhart (Mr.
3On Jan. 24, 2000, Ms. Norquist filed a form with the U.S.
Postal Service to change her address from the Aspen address to
1438-B Bishop’s Lodge Road, Santa Fe, New Mexico 87501. Ms.
Norquist and her husband, James Walter Dickson, used this new
address on their 1999 and 2000 joint income tax returns.
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Last modified: May 25, 2011