Estate of Melvine B. Atkinson, Deceased, Christopher J. MacQuarrie, Personal Representative - Page 8




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          obtaining client files from his previous firm that were needed to           
          complete the estate’s tax returns.5  Mr. Feist declined Mr.                 
          William’s request for another extension and told Mr. Williams               
          that the hearing would be held that day, either in-person or                
          telephonically.                                                             
               A telephonic collection hearing was held on December 17,               
          2004, between Mr. Feist and Mr. Williams.  During the hearing,              
          Mr. Feist declined to discuss collection alternatives, explaining           
          to Mr. Williams that the estate was precluded from collection               
          alternatives due to its delinquent tax returns, and informed Mr.            
          Williams that he would issue a notice of determination sustaining           
          the levy.  Mr. Feist provided Mr. Williams with the following               
          suggestions:  (1) Forward the delinquent returns and old                    
          brokerage statements to Ms. Clark; (2) estimate the remaining               
          administrative costs needed to close the estate (including the              
          collection activity); and (3) pay to respondent the money the               
          estate receives from the Mayo Clinic.6                                      



               5Mr. Williams changed law firms from Akerman Senterfitt to             
          Straley Robin & Williams, both of which were located in Tampa,              
          Florida.  Mr. Williams was experiencing difficulty in obtaining             
          files because of an alleged dispute between the estate and                  
          Akerman Senterfitt over allegedly unpaid fees related to the                
          estate’s litigation in the Tax Court and the Court of Appeals for           
          the Eleventh Circuit.                                                       
               6The estate was to request the return of approximately                 
          $340,000 in charitable distributions to the Mayo Clinic.                    






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