📄 Extracted Text (605 words)
To: Ellen Harrison
From: Jeffrey Epstei
Sent Mon 1/13/2014 1:51:05 PM
Subject: Re: M
where and when is the COD?
On Mon, Jan 13, 2014 at 9:25 AM, Ellen Harrison wrote:
On your question about Mort's basis in the notes, I checked with Brian and He said the notes
had not been written down so I gave you bad information. Sony.
In my opinion, your purchase of the receivables from Mon would not cure the COD issue we
are worried about. Even if the sale generated a capital loss, that would not offset ordinary
income from COD. However, we will continue to explore this along with other ideas
My partner is working on an accounting for the 1983 and 1996 trusts. She is still getting data.
This has been in process for less than a month. I expect that it will be some time before it is
done because I am told that the records prior to 2000 are limited.
SRR is appraising R&R. We are hoping, of course, that the cash flow will be sufficient to cover
the preference. Since we don't have the appraisal or the preference yet we don't know whether
this will be a problem. If it is, I would use debt to reduce value so cash flow would cover the
preference. This is a problem under section 2701, because the common has to equal 10% of
enterprise value before debt, but we will figure it out.
Sent from my iPhone
On Jan 13, 2014, at 7:19 AM, Jeffrey Epstein <[email protected]> wrote:
EH you told me that morts basis in the 12 percent notes had been written
down, can you explain, . can you tell me the status of the trust accounting to
date. ? you stated that Rand R was being valued, and planned to put it in a
preferred partnership. ? what is the plan if the cashflow is not enough to pay the
preferred. ?
On Sun, Jan 12, 2014 at 2:30 PM, Ellen Harrison wrote:
> Hello
> I just left you a voicemail. I would like to speak with you briefly about the terms of the
deal you proposed to MZ so that we can give it appropriate analysis. Could you
please give me a call at or reply to this email as soon as possible?
We are trying to schedule a conference call with tax advisors on Monday
between 10 and 12 and it would be very helpful to have your proposal in hand by
then.
EFTA_R1_00394542
EFTA01937942
> Thanks and Happy New Year.
> Sent from my iPhone
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