EFTA00429378.pdf

From: Darren Indyke To: > Subject: Fwd: Tax Ownership Date: Wed, 10 Aug 2011 22:46:04 +0000 Attachments: raskolnikov.tax.ownership.pdf Please print the attachment. Darren K. Indyke Darren K. Indyke, PLLC 301 East 66th Street, 10B New York, New York 10065 Telephone: Direct: Fax: (212) 517-7779 email: ********************************************************************************************** The information contained in this communication is confidential, may be attorney-client privileged, and is intended only for the use of the addressee. It is the property of Darren K. Indyke, PLLC. 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, and destroy this communication and all copies thereof, including all attachments. Copyright of Darren K. Indyke, PLLC - © 2011 Darren K. Indyke, PLLC —All rights reserved. *********************************************************************************************** Begin forwarded message: From: "Verdolini, Mario J." <I Date: August 10, 2011 5:47:24 PM EDT To: "I > Cc: "Windels, James H.R." < >, "Barbieri, Dominick D." Subject: Tax Ownership Dear Darren, As I mentioned in our call, the law on tax ownership is mostly in the case law rather than the Internal Revenue Code. The attached article summarizes the legal standards for fungible and non-fungible property. The present situation would involve the latter category. Please let me know if you would like to discuss this further. Regards, Mario Mario J. Verdolini EFTA00429378 Davis Polk & Wardwell LLP 450 Lexington Avenue New York, NY 10017 tel 212 701 5969 fax EFTA00429379