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An estate tax return was filed for decedent on September 13,
1994. Thereafter, respondent audited the estate and determined a
deficiency. In response, the estate timely petitioned this
Court. The Court found that the estate was liable for a reduced
deficiency. See Estate of Atkinson v. Commissioner, 115 T.C. 26
(2000), affd. 309 F.3d 1290 (11th Cir. 2002). On January 24,
2002, a deficiency of $717,790 plus interest was assessed against
the estate.
Respondent issued to the estate a Notice of Federal Tax Lien
Filing and Your Right to a Hearing Under IRC 6320 on March 10,
2004, with respect to the estate’s unpaid estate tax. The estate
did not respond. Respondent then issued to Mr. MacQuarrie a
summons for appearance on April 6, 2004, at respondent’s Ocala,
Florida, office. Additionally, the summons required Mr.
MacQuarrie to bring to his summons appearance the following
documents relating to the period of June 7, 1993, to March 1,
2004: (1) A listing of all assets of the estate; (2) copies of
statements of all bank accounts, stock accounts, or other asset
accounts owned or controlled by the estate; (3) copies of all
canceled checks for any bank accounts owned or controlled by the
estate; and (4) a listing of all distributions made from the
assets of the estate by source, date, amount, and payee.
Mr. MacQuarrie designated his attorney, Robert S. Williams
(Mr. Williams), as his attorney-in-fact, on March 30, 2004, by
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