EFTA02618560.pdf

From: jeffrey E. <[email protected]> Sent: Wednesday, September 20, 2017 3:03 AM To: Barry J. Cohen Subject: Re: Phaidon Its ok. Happy new year. Talk next week </=iv> On Tue, Sep 19, 2017 at 9:11 PM Bar=y J. Cohen c • 5.6 EY people have told us that they have experience with audits. =AO I thought I gave you all the names before. I will get you a list =f everyone we talk to at every firm who has audit experience! Sent from my iPhone On Sep 19, 2017, at 7:04 PM, jeffrey E. <[email protected] <mailto:jeevacation@g=ail.com» wrote: do they have names ?" 7"IIIII On Tue Se 19 2017 at 5:28 PM, Barry J. Cohen =span> <mailt wrote: Phaidon may be $30MM. =br> =ou are consumed with audit experience! Some of our tax team (mostly =Y) have it. Others less so. Sent from my iPhone On Sep 19, 2017, at 5:09 PM, jeffrey E. <[email protected] <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> <mailto > wrote: EFTA_R1_01822404 EFTA02618560  He is agreeing with you on gift tax returns. =an't leave everything blank. From: jeffrey E. [mailto:[email protected] 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 On Tue Se 19 2017 at 4:19 PM Barr J. Cohen <=a href="mailto wrote: Fair enough. From: jeffrey E. [mailto:[email protected] Sent: Tuesday, Se tember 19, 2017 4:19 PM To: Barry J. Cohe Subject: Re: 000's dumb' II, as i told you, =omputers dont read letters On Tue, Sep 19, 2017 at 4:15 PM, Barry!. Cohen <=a href="mailto =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:[email protected] Sent: Tuesday, September 19 20174:09 PM To: Barry J. Cohe Subject: Re: 000's 2 EFTA_R1_01822405 EFTA02618561  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, 1099$, 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? <https://maps.goog=e.comnq=445+Park+Avenue+Suite+1401 %0D+New+York,+NY+10022+%3Chttps:/=ma ps.google.com/?q%3D445%2BPark%2BAvenue%2BSuite%281401%250D%2BNew%2BYork,=2BNY%21310022%26entry%3 Dgmail%26source%3Dg%3E&entry=gmail&source=3Dg> Joe V likes the idea of putting in 0's i=stead of blanks. He says he uses "none". He di= not understand why this would affect the statute of limitations. Barry J. Cohen =A0I Elysium Management,=LIC 445 Park Avenue Suite 1401 <https://maps.google.com/?q=445+Park+Ave=ue+Suite+1401%0D+New+York,+NY+10022&entry=gmail&source=g> New York, NY 10022 <https://maps.google.com/?q=445+Park+Ave=ue+Suite+1401%0D+New+York,+NY+10022&entry=gmail&source=g> = please no=e 3 EFTA_R1_01822406 EFTA02618562  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 [email protected] <mailto:[email protected]> , 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 [email protected] <mailto:[email protected]> , 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 4 EFTA_R1_01822407 EFTA02618563  return e-mail or by e-mail to [email protected] <mailto:[email protected]> , 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 [email protected] <mailto:[email protected]> 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 [email protected] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved =C2 please note 5 EFTA_R1_01822408 EFTA02618564 The information co=tained in this communication is confidential, may be attorney-client pr=vileged, may constitute inside information, and is intended only for JEE Unauthorized use= disclosure or copying of this communication or any part thereof is str=ctly prohibited and may be unlawful. If you have received this commu=ication in error, please notify us immediately by return e-mail or by e=mail to [email protected] <[email protected]> , and destroy this communication and all copies thereo=, including all attachments. copyright -all rights reserved </=iv> --94eb2c1c1ddc9b649c05599636e0-- conversation-id 31027 date-last-viewed 0 date-received 1505876579 flags 8590195713 gmail-label-ids 7 6 remote-id 751533 6 EFTA_R1_01822409 EFTA02618565