EFTA02702942.pdf

From: Thomas Turrin Sent: Tuesday, May 10, 2016 4:34 PM To: Halperin, Alan 5; Jeffrey E. Subject: RE: GIFT TAX AUDIT Attachments: Bryant Grp - 2013 Split Dollar Life Insurance.pdf The password is my off=ce zip code. The reportable gift am=unt related to the split dollar insurance is attached — as sub=itted annually by Bryant Group. =nbsp; THOMAS TURRIN, CPA<=p> Partner Raich Ende Malter & =o. LLP 1375 Broadway<=o:p> New York, New York =0018 ext 2=04) (Dire=t line) (Fax)=0:p> (Cell= Email: Website: www.rem-co.com 1 EFTA_R1_02077142 EFTA02702942 From: Halperin= Alan S Sent: Tuesday, May 10, 2016 12:11 PM To: Thomas Turrin; jeffrey E. Subject: RE: GIFT TAX AUDIT Thanks. I am working o= a proposed response to the IRS letter. Could you tell me how the gift amo=nt relating to the split dollar insurance arrangement was determined and s=nd me the supporting document? Alan Alan S. Halperin</=pan> I Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 10019.6064 www.paulweiss.com <http://www.paulweiss.com> From: Thomas Turrin Sent: Tuesday, May 10, 2016 10:48 AM To: Jeffrey E. <[email protected] <mailto:[email protected]»; Halperin, Alan S Subject: GIFT TAX AUDIT Alan and Jeffrey, The agent finally called me this morning. = He was apologetic that he didn't call sooner. He said hea;s been in and out of the office the last couple of weeks.</=> He was very nice on the phone....saying we can h=ve more time to get him the information requested. 2 EFTA_R1_02077143 EFTA02702943 However, he said to contact him by the end of May if=we still need more time. He said he would grant more time, if necessary. I would hope we can get the response done as soon as=possible so we don't have to ask for more time. The bad news is that they will also examine 2014.&nb=p; He told me a letter will go out soon. Mr. Falk readily volunteered that it is the GRATS (s=ecifically the valuations) that are kicking off the audits. He did say that he would try to "move the audi=s along".... He also said he sees (and audits) valuations from Empire all the time. I'm reachable all day, if you would like to ca=l. Tom THOMAS TURRIN, CPAap> Partner Raich Ende Malter & =o. LLP 1375 Broadway<=o:p> New York, New York =0018 ext 2=04) (Dire=t line) (Fax)=o:p> (Cell= Email: 3 EFTA_R1_02077144 EFTA02702944 Website: www.rem•co.com &n=sp; &=bsp; CONFIDENTIALITY STATEMENT=/strong>: The information c=ntained in this electronic communication, including any and all attachments and en=losures, may be privileged and is strictly confidential, intended solely f=r the use of the person(s) identified above to receive this communication.=lf you are not the person(s) identified above to receive this communication, you are hereby notified that you may =ot disclose print, copy, disseminate, or otherwise use the information con=ained herein. If you are an employee or agent of the person(s) identified =bove to receive this communication and, as such, you have been authorized to deliver this communication to su=h person(s), you may disclose, print, copy, disseminate, or otherwise use =he information contained in this communication solely for the purpose of s=ch delivery. Unauthorized interception and/or use of this communication are/is strictly prohibited and may be pun=shable by law. If you have received this communication in error, please re=ly and notify the sender (only) of that fact and delete the communication,=including any and all attachments and enclosures, from your computer or other electronic device on which you=may have received this communication. This message is intended only for the use of the Addressee =nd may contain information that is privileged and confidential. If you are=not the intended recipient, you are hereby notified that any dissemination of this communication is strictly prohibited. If you hav= received this communication in error, please erase all copies of the mess=ge and its attachments and notify us immediately. 4 EFTA_R1_02077145 EFTA02702945