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executing and delivering to respondent an Internal Revenue
Service (IRS) Form 2848, Power of Attorney and Declaration of
Representative. Mr. Williams began correspondence with Amelia
Clark (Ms. Clark), the revenue officer appointed to handle the
estate’s unpaid tax liabilities. On April 5, 2004, the day
before Mr. MacQuarrie was to appear in response to the summons,
Mr. Williams spoke with Ms. Clark and requested that the summons
appearance date be rescheduled to April 13, 2004.
On April 13, 2004, Mr. MacQuarrie and Mr. Williams met with
Ms. Clark and her manager, Richard Bartholomew, at the IRS office
in Ocala, Florida, to discuss the following: (1) The filing
status of the estate’s tax returns; (2) the current assets and
liabilities of the estate; (3) the administrative expenses of the
estate; (4) charitable distributions of approximately $340,000 to
the Mayo Clinic from the estate; and (5) some personal affairs of
Mr. MacQuarrie. During the meeting, Ms. Clark prepared a
financial statement for the estate based on the information
provided by Mr. MacQuarrie and Mr. Williams, but Mr. MacQuarrie,
acting on advice from Mr. Williams, declined to sign the
statement. At the end of the meeting, Ms. Clark informed Mr.
MacQaurrie and Mr. Williams that the estate’s delinquent tax
returns were to be filed within 30 days and that Mr. MacQuarrie
needed to submit a signed financial statement for the estate.
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Last modified: November 10, 2007