EFTA01047727.pdf

From: "jeffrey E." <[email protected]> To: "Barry J. Cohen" <I >, Brad Wechsler Bcc: Leon Black -41 Subject: Re: Alternative IRS Response Letter--PRIVILEGED AND CONFIDENTUAL Date: Sat, 29 Apr 2017 14:15:26 +0000 Difficult to justify a position to IRS if we can't even justify to ourselves ! On Sat, Apr 29, 2017 at 9:42 AM jeffrey E. [email protected]> wrote: Let's get to that answer On Sat, Apr 29, 2017 at 9:29 AM Barry J. Cohen wrote: But why would lots of other Apollo people be getting something similar if this is just about a Tom Turin mistake? Sent from my iPhone On Apr 29, 2017, at 8:46 AM, jeffrey E. <[email protected]> wrote: Irs says 880 understatement. TOM says 880 loss not gain . Soo. Sloppy it's difficult to decode On Sat, Apr 29, 2017 at 8:31 AM Barry J. Cohen -4 l> wrote: I agree the alternative letter is not great. Note that the IRS's first letter suggests that the BRH numbers are fine, but they can't figure out how we applied them to the return. The IRS's second letter suggests the BRH numbers are wrong and have now been corrected. That leaves the possibility that the IRS is unsure how the new BRH numbers are applied to the return. Even though they appear to have concluded how much we owe. So if the IRS never returns our call, it is hard to know what to do. Sent from my iPhone On Apr 29, 2017, at 1:50 AM, jeffrey E. <[email protected]> wrote: Needs work , I think we might want to submit part . Explanation details .Joslin should do 54 m of income report . In similar but clearer fashion . Recall. 8865 requires not under audit ?? On Fri, Apr 28, 2017 at 6:03 PM Barry J. Cohen wrote: If we want to take the position that the second letter from the IRS obviates the need to send the package we just sent you, attached is an alternate letter we could send in response to the first IRS letter. From: Brad Wechsler Sent: Friday, April 28, 2017 5:59 PM To: Barry J. Cohen Subject: Fw: Alternative IRS Response Letter EFTA01047727  Maybe forward to jee to think abt and/or edit? Sent from my Verizon Wireless BlacicBerty From: "Barry J. Cohen" Date: Fri, 28 Apr 2017 21:52:14 +0000 To: Brad Wechsler Cc: Yvonne Berger< Subject: Alternative IRS Response Letter As I will be out of town Mon.-Wed., please hold on to this in case you need it. Barry J. Cohen I Elysium Management, LLC 445 Park Avenue Suite 1401 New York, NY 10022 I 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], 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 EFTA01047728  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], 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, 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, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA01047729