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On June 1, 2004, Ms. Clark spoke with Mr. Williams and
requested the following: (1) Charles Schwab account information
from January 1, 1999, through June 1, 2004, for the trusts;
(2) information about the class action lawsuits in which the
estate was a class member;4 (3) information about the estate’s
real estate; (4) an original signed copy of the estate’s
financial statements, including those of the trusts; (5) a copy
of the estate’s court pleadings regarding fees; and (6) Mr.
MacQuarrie’s presence at the next meeting. Shortly after Ms.
Clark’s and Mr. Williams’ telephone conversation, the estate
received by mail A Notice of Intent to Levy and Your Right to a
Hearing, which had been issued by respondent on May 27, 2004. In
response, the estate timely submitted a Form 12153, Request for a
Collection Due Process Hearing, on June 20, 2004. In an
attachment to Form 12153, Mr. Williams described the estate’s
disagreement with the levy, in pertinent part, as follows:
The collection action in this case is premature, and
the Internal Revenue Service should grant an extension
of time to pay the outstanding estate taxes. The
assets remaining in the Estate consist of cash and
security class action lawsuits of unknown value. The
cash remaining in the Estate is needed for
administrative expenses to deal with the outstanding
tax liability and the class action lawsuits.
The class action lawsuits have no value that can be
determined at this time, but have significant
potential. However, the expenses of levying them could
4The estate was a class member in the Citigroup, Sun Micro
Systems, TYCO, and Worldcom class action lawsuits.
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