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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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