EFTA02619466.pdf

From: jeffrey E. <jeevacation@gmail.com> Sent: Tuesday, September 19, 2017 11:04 PM To: Barry J. Cohen Subject: Re: Phaidon do they have names 22227211111 On Tue, Sep 19, =017 at 5:28 PM, Barry J. Cohen > wrote:=br> Phaidon may be $30MM. You are consumed with =udit experience! Some of our tax team (mostly EY) have it. Oth=rs less so. Sent from my iPhone On Sep 19, 2017, at 5:09 PM, jeffrey E. <jeevacation@gmail.com <mailto:jeevacation@g=ail.com» wrote: I actually dont care whether or not he agrees . I would as= that you merely inquire as to how many 1040 fed audits 1040 l=rge case or 10 40 wealth squad audits hes actually managed or partcipated =n. how much loss do you think you can generate this year with a phaidon transa=tion.? On Tue, Sep 19, 2017 at 4:29 PM, Barry J. Cohen =span dir="ltr"> <mailto > wrote: He is agreeing with you on gift tax returns. =an't leave everything blank. From: jeffrey E. [mailto:jeevacation@gmail.comj Sent: Tuesday, September 19, 2017 4:25 PM To: Barry J. Cohen < Subject: Re: 000's think about it, again, ask j=e how many 1040 audits he has done. . what size. h=w complex. when we file a grat, we cal=late the gift explicity at zero. . it =s the calculation of a gift minus the annuity. It is sim=le math. no more 2 minus ( 1+=) does not equal NONE EFTA_R1_01824304 EFTA02619466  On Tue, Sep 19, 2017 at 4:19 PM, Barry J. Cohen <=a href="mailto target="_blank" =a» wrote: Fair enough. From: Jeffrey E. [mailto:jeevacation@gmail.com] Sent: Tuesday, September 19, 2017 4:19 PM TO: Barry J. Cohen nillINS > Subject: Re: 000's dumb 'lullI as i told you, =omputers dont read letters On Tue, Sep 19, 2017 at 4:15 PM, Barry J. Cohen <=a href="mailto " target="_blank"> <=a» wrote: Sorry I misunderstood on the 000s. Gift tax r=turns have to report a number somewhere, so maybe statute doesn't =tart. But if you filed an income tax return for an entity with no income or expenses, Joe V assumes the statute would start. 1= any event, we don't file returns that way. As I said, we wo=ld say "None" where appropriate. From: Jeffrey E. [mailto:jeevacation@gmail.com] Sent: Tuesday, September 19, 2017 4:09 PM To: Barry J. Cohen > Subject: Re: 000's i did not suggest you use the 000 method. =AO Im sorry but i dont have the time . do yo= think if you filed a gift tax return and left everything blank the =tatue would run? On Tue, Sep 19, 2017 at 4:03 PM, Barry J. Cohen <=a href="mailto a» wrote: John Cook at EY said they would not sign a return th=t uses the 000s method. They said that there are too many footing pr=blems. Numbers won't tie to K-ls, W-2s, 1099s, etc. Al=o, if you only use it on part of the return, the various numbers on the return would not match internally. He also pointed ou= that this method effectively truncates numbers; though I'm not su=e what rounding rules you use. E.g., 101,499 become 101? What =appens to the other $499? 2 EFTA_R1_01824305 EFTA02619467  Joe V likes the idea of putting in 0's inste=d of blanks. He says he uses "none". He did no= understand why this would affect the statute of limitations. Barry J. Cohen =AOI Elysium Management,=L1C 445 Park Avenue Suite 1401 chttps://maps.google.comilq=445+Park+Ave=ue+Suite+1401%0D+New+York,+NY+10022&entry=gmail&source=g> New York, NY 10022 <https://maps.google.com/k=445+Park+Ave=ue+Suite+1401°A0D+New+York,+NY+10022&entry=gmail&source=g> = Tel. I Cell <tel 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 <mailtojeevacation@gmail.com> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please no=e The information contained in this communication is confidential, may be attorney-client privileged, may 3 EFTA_R1_01824306 EFTA02619468  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 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 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 <mailtoleevacation@gmail.com> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved 4 EFTA_R1_01824307 EFTA02619469  =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 --001a114ea86a163ad3055992eOff-- conversation-id 31027 date-last-viewed 0 date-received 1505862243 flags 8590195713 gmail-label-ids 7 6 remote-id 751428 5 EFTA_R1_01824308 EFTA02619470