EFTA00962009.pdf

From: "Fenn, Patrick" < To: <[email protected]> Subject: Planning Date: Sat, 01 Jun 2013 02:03:18 +0000 Attachments: Negative_basis_104773603(6).DOCX Jeffrey, I have asked one of my partners to review this but he has not been able to do so as yet. I am sending to you as a draft with that in mind. I can update over the weekend for his comments. I would suggest running it by Brian Knudson at EY as well but will wait for your reaction before doing so. Best regards Patrick B. Fenn AKIN GUMP STRAUSS HAUER & FELD LLP One Bryant Park I New York, NY 10036-6745 USA Direct: I Internal: 31040 Fax: laNIMIN I I IRS Circular 230 Notice Requirement: This communication is not given in the form of a covered opinion, within the meaning of Circular 230 issued by the United States Secretary of the Treasury. Thus, we are required to inform you that you cannot rely upon any tax advice contained in this communication for the purpose of avoiding United States federal tax penalties. In addition, any tax advice contained in this communication may not be used to promote, market or recommend a transaction to another party. The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message. EFTA00962009