EFTA01047718.pdf

From: "Barry J. Cohen" < To: jeffrey E. <jeevacation®grnail.com> CC: Leon Black >, Subject: Re: Alternative IRS Response Letter Date: Sat, 29 Apr 2017 13:27:16 +0000 I think the issue is more a matter of how we file. If, say, BRH issues a K-1 to Black Family Partners, do we file something at least indicating that BFP received it and flowed it through to downstream entities? Versus just flowing things through to the ultimate taxpayer without explanation. Sent from my iPhone On Apr 29, 2017, at 9:21 AM, jeffrey E. <jeevacation@gmail.com> wrote: Hopefullt this exvercise will illustrate the issues that you two need to address . Systems -accurate numbers , clear concise reporting etc On Sat, Apr 29, 2017 at 9:00 AM < wrote: Rich is working on 54mm of "business income" and the six or so other categories besides interest (already forwarded) this weekend. Goal is to have a fairly complete package by monday. I expect each category of income to present unique issues in terms of "simple/clear" back-up. As barry notes, we'll have to figure out early next week what our best response to irs is (and you mentioned what type of package, if any, we want to send to irs. I told tom NOT to reach out to IRS monday am without speaking to you for scripting. B Sent from my Verizon Wireless BlackBerry From: "jeffrey E." <jeesinti@gmail.com> Date: Sat, 29 Apr 2017 05:50:04 +0000 To: Barry J. Cohen ; Brad Wechsler >; Leon Black Subject: Re: FW: Alternative IRS Response Letter Needs work , I think we might want to submit part . Explanation details .Joslin should do 54 m of income report . In similar but clearer fashion . Recall. 8865 requires not under audit ?? On Fri, Apr 28, 2017 at 6:03 PM Barry J. Cohen <I > wrote: If we want to take the position that the second letter from the IRS obviates the need to send the package we just sent you, attached is an alternate letter we could send in response to the first IRS letter. From: Brad Wechsler Sent: Friday, April 28, 2017 5:59 PM To: Barry J. Cohen Subject: Fw: Alternative IRS Response Letter Maybe forward to jee to think abt and/or edit? Sent from my Verizon Wireless BlackBerry EFTA01047718  From: "Barry J. Cohen" < Date: Fri, 28 Apr 2017 21:52:14 +0000 To: Brad Wechsler Cc: Yvonne Bergercl Subject: Alternative IRS Response Letter As I will be out of town Mon.-Wed., please hold on to this in case you need it. Barry J. Cohen I Elysium Management, LLC 445 Park Avenue Suite 1401 New York, NY 10022 I please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jeevacation@gmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by EFTA01047719 return e-mail or by e-mail to jeevacation@gmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA01047720