EFTA01783116.pdf

From: Fenn, Patrick < Sent: Friday, SeptemM.1 el- 11:4 P i To: jee' Subject: RE: Re: Name a time and I'l= send a dial in number. From: jee Imai=to:jeevacation@gmail.comj Sent: Friday, September 09, 2016 7:40 AM To: Fenn, Patrick Subject: Re: tomorrow On Sep 9, 2016, at 7:39 AM, Fenn, Patrick avrote: When can you speak wi=h me and Karp? Patrick B. Fenn=o:p> AKIN GUMP STRAUSS H=UER & FELD LLP Direct: On Sep 9, 2016, at 6:01 AM, jeffrey E. <jeevacation@gmail.com <mailto:jeevacation@gm=il.com> wrote: each preparer or the law firm acting on =ehalf of the client? On Thu, Sep 8, 2016 at 10:26 PM, Fenn, Patrick «= href EFTA_R1_00103491 EFTA01783116  Each preparer firm (f=r the individuals) would say that you mean? Not Deloitte. Delo=tte prepared the underlying AOG/BRH returns. Patrick B. Fenn=o:p> AKIN GUMP STRAUSS H=UER & FELD LLP Direct: =nbsp; On Sep 8, 2016, at 9:52 PM, jeffrey E. <jeevacation@gmail.com <mailto:jeevacation@gm=il.com» wrote:<=p> re 2. they should represent the fa=t that the taxpayer never got the info . its not a=fault situation. . . but a third party confirming that t=e principals did not act willfully On Thu, Sep 8, 2016 at 9:43 PM, Fenn, Patrit Jeffrey, See responses below. Let me know when you can =peak with Karp in the next few days. Thanks Patrick B. Fenn=o:p> AKIN GUMP STRAUSS H=UER & FELD LLP Direct bsp; On Sep 8, 2016, at 8:14 PM, jeffrey E. <jeevacation@gmail.com <mailto:jeevacation@gm=il.com> wrote:<=p> 1 do you believe penalties will be asses=ed on late filing. 2 EFTA_R1_00103492 EFTA01783117  I think not. Our reasonable cause statement is=solid based on the information we have at this point. 2. is there a reason that the letter should no= come from either the preparer or accounting firm and signed by prin=ipal. or their respective law firm, I can't think of any reason other than I don't think=you are going to get the accounting firm to say in writing it was their fa=lt if that is your goal. They will state the facts -- that they were=hired to prepare the return, that they are experts, and that they failed to include the information return. = 3. you have represented that no audits a=e open, Confirming with family offices/Alan. 4 have we checked that all potential outbound or inb=und transactions were reported properly, on each of the princi=als return. . Despite my efforts to get preparer firms focused on =iccups outside the Apollo sphere and the 8865 data, that process has yet t= begin pending receiving info from Apollo. There is some logic in th=t. 5. are we certain that it is only the informat=on returns and there are no substantial change in numbers. Same as S. 3 EFTA_R1_00103493 EFTA01783118  6. at a minimum we should check that the infor=ation returns to be filed with the 1040x matches the returns f=led. Agreed. 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 <mailtcrjeevacation@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. please no=e The information contained in this communication is confidential, may be attorney-client privileged, may 4 EFTA_R1_00103494 EFTA01783119  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. 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. 5 EFTA_R1_00103495 EFTA01783120 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. 6 EFTA_R1_00103496 EFTA01783121