EFTA02450447.pdf

From: jeffrey E. <jeevacation@gmail.com> Sent: Sunday, September 11, 2016 12:52 AM To: Pesner, Steven Cc: Fenn, Patrick; Karp, Brad S Subject: Re: Reasonable cause statement can josh harris join the call tomorrow? =ight be very helpful. On Sat, Sep 10, 2016 at 8:30 AM, Pesner, Steven <rnailto: > wrote: ok</=> From: Fenn, Pa=rick Sent: Saturday, September 10, 2016 8:28 AM To: Karp, Brad S Cc: jeeva=ation@gmail.com <mailto:jeevacation@gmail.com> ; Pesner, Steven Subject: Re: Reasonable cause statement That works for me. =C2 Patrick B. Fenn=u> AKIN GUMP STRAUSS H=UER & FELD LLP Direct: <tel On Sep 9, 2016, at 11:26 PM, Karp, Brad S > wrote: How about Sunday at 10 am= Brad S. Karp I Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 10019.6064 EFTA_R1_01549375 EFTA02450447  ctel: (Direct Phone) <tel (Direct Fax) <=r = <mailto > www.paulweiss.com <http://www.paulweiss.com> From: Fenn, Pa=rick imailto anailtoa Sent: Friday, September 09, 2016 11:10 PM To: Karp, Brad S Cc: jeeva=ation@gmail.com <mailto:jeevacation@gmail.com> <jeevacation@gmail.com <mailto:jeevacation@gmail.com»; <mailto: Subject: Re: Reasonable cause statement That works for me as well. Patrick B. Fenn=u> AKIN GUMP STRAUSS H=UER & FELD LIP Direct: <tel: On Sep 9, 2016, at 10:29 PM, Karp, Brad S <mailto >> wrote: I can speak any time befo=e 1 pm. Brad S. Karp j Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 10019-6064 <tel: (Direct Phone) <tel > (Direct Fax) <=r> <mailto I www.paulweiss.com <http://www.paulweiss.com> From: Fenn, Pa=rick (maiIto <mailto:a Sent: Friday, September 09, 2016 08:15 PM To: jeffrey E. <jeevacation@gmail.com <mailtoleevacation@gmail.com» Cc: Karp, Brad S 2 EFTA_R1_01549376 EFTA02450448  Subject: Re: Reasonable cause statement <=p> Did we establish a ti=e to speak tomorrow? Patrick B. Fenn=u> AKIN GUMP STRAUSS H=UER & FELD LLP Direct: <tel: On Sep 9, 2016, at 7:10 PM, jeffrey E. <jeevacation@gmail.com <mailto:jeevacation@gm=il.com> wrote:</=> i think we might consider attaching affidavit=from Apollo - preparer and accounting firm support=ng the actual events. . this is of course as long =s the numbers also tie. . it is true that technically =A0 each filing requires its own reasonable letter. but Pm uncertain whether=one letter that states with specificity, that it applies=to each one by name and year, would qualify. tha= being said one hundred letters and three h=ndred affidavits plus 100 8865s plus 8 1040xs. is quite a package On Fri, Sep 9, 2016 at 6:35 PM, Fenn, Patrick <maittoS <=p> Will rework over the week=nd for this. </=> From: Jeffrey =. imailto:jeeva=ation@gmailcom <mailto:jeevacation@gmail.com> Sent: Friday, September 09, 2016 6:32 PM To: Fenn, Patrick Subject: Re: Reasonable cause statement thx, thoughts for discussioin. i suggest we beef up the backround at a miimum , always =iled on time non deliqent n any filing.. blah blah, =AO resposnilble . biz exec. complex returns alwsays on t=me. no jdugements etc. a character paragraph.. =AO a tax history of no changes? , hired both accounts and lawfirms in the preparation.? . it i= a joint return , do we need to include debra.? i =ould destres the he didnt know. and add that apollo thou=ht and advised otherwise? do we add al= the patners treated the same , no one filed. only in a compliance review=C2 did it get flagged? 3 EFTA_R1_01549377 EFTA02450449  On Fri, Sep 9, 2016 at 6:25 PM, Fenn, Patrick <mailto <=p> As discussed. Patrick B. Fenn AKIN GUMP STRAUSS HAUER & FELD LLP I New York, NY 10036-6745 I USA I Direct: cella <=> Internal <tea Fax: <tel: > <rnailto > I akingump.com <https://urldefense.proofpoint.=om/v2/url?u=http- 3A www.akingump.com&d=CwMFaQ&c=MVcBZOqZGZI=cau2IIMSkQ&r=kYDaj3HOMbdAmySpaefyaL_7ivfBgLlqlMsd- G22lyk&m=YCo=7d-c-1--OrOToUOAGy6arUelTIbkIHckvKJBY80&s=5GOUPbchdOBcPIGqhvMM3- yGwk=XUVtXGQWucebPiRQ&e=> I Bio <https://urldefense.proofpoi=t.com/v2/url?u=http- 3A_www.akingump.com_pfenn&d=CwMFaQ&c=MV=BZOqZGZIJcau2llMSkQ&r=kYDaj3HQMbdAmySpaefyaL_7ivfBgL1q IMsd-G22lyk&arn=;m=4CoY7d-c-1-- OrOToUOAGy6arUeZTIbkIHckvIUBY80&s=N8wEdbYndziNNeOL0=RmhkloDeylsx1ULaUldTcbgnA&e=> The information contained in this e-mail message is intended only for the p=rsonal and confidential use of the recipient(s) named above. If you have r=ceived this communication in error, please notify us immediately by e-mail= and delete the original message. please no=e 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 <mailto:jeevacation@gmail.com> and 4 EFTA_R1_01549378 EFTA02450450  destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved The information contained in this e-mail message is intended only for the p=rsonal and confidential use of the recipient(s) named above. If you have r=ceived this communication in error, please notify us immediately by e-mail= and delete the original message. please no=e 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 <mailto:jeevacation@gmail.com> and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved The information contained in this e-mail message is intended only for the p=rsonal and confidential use of the recipient(s) named above. If you have r=ceived this communication in error, please notify us immediately by e-mail= and delete the original message. This message is intended only for the use of the Addressee =nd may contain information that is privileged and confidential. If you are=not the intended recipient, you are hereby notified that any dissemination of this communication is strictly prohibited. If you hav= received this communication in error, please erase all copies of the mess=ge and its attachments and notify us immediately. The information contained in this e-mail message is intended only for the p=rsonal and confidential use of the recipient(s) named above. If you have r=ceived this communication in error, please notify us immediately by e- mail= and delete the original message. 5 EFTA_R1_01549379 EFTA02450451  The information contained in this e-mail message is intended only for t=e personal and confidential use of the recipient(s) named above. If you ha=e received this communication in error, please notify us immediately by e-=ail, and delete the original message. =AO please note The information contained i= this communication is confidential, may be attorney-client privileged,=may constitute inside information, and is intended only for the use =f the addressee. It is the property of JEE Unauthorized use, disclos=re or copying of this communication or any part thereof is strictly pro=ibited and may be unlawful. If you have received this communication =n error, please notify us immediately by return e-mail or by e-mail to =a href="mailto:jeevacation@gmail.com" target="_blank">jeevacation@gmai=.com, and destroy this communication and all copies thereof, inc=uding all attachments. copyright -all rights reserved 6 EFTA_R1_01549380 EFTA02450452