EFTA02657507.pdf

From: Richard Kahn < Sent: Monday, May 21, 2018 8:41 PM To: Jeffrey E. Subject: max Richard Kahn HBRK Associates Inc. 575 =exington Avenue 4th Floor New York, NY 10022 tel fax cell Begin forwarded message: From: =/b>Max Kohlenberg < Subject: =/b>Re: Date: =/b>May 21, 2018 at 4:40:19 PM =DT To: =/b>Richard Kahn < In a meeting Rich, so =rief answers. There is no prohibition, but specific IRS rules and =ase law to acknowledge and comply with. Not something to be done =ithout trust lawyers involved. I have not calculated what the =axes would be if done wrong - not an acceptable outcome for =nyone. Sent from my Verizon, Samsung Galaxy =martphone Original =essage From: Richard Kahn < Date: =121/18 4:07 PM (GMT-05:00 To: =ax Kohlenberg < <mailto >> Subject: Re: 1 EFTA_R1_01903748 EFTA02657507  i am aware of the rule as we =iscussed but this is hardly a difficult issue and certainly not a =rohibition. that is nonsense. also have you =alcuated the amount. as i do not know the original =mounts? Richard Kahn HBRK =ssociates Inc. 575 Lexington Avenue 4th Floor New York, NY 10022 tel fax cell > On May 21, 2018, at 3:45 PM, Max =ohlenberg < <mailto > wrote: > Rich = > Sorry for the delay on the income distribution =nformation. I'll try to get that for you tomorrow. •> I'm afraid I disagree (as does Harry's attorney) as to =he existence of legal issues relating to liquidation of the =rusts. As you know, the trusts avoided federal and Massachusetts =state tax at Carol's death by virtue of qualifying for the marital =eduction. Unless the termination is handled properly the deferred =ax could be triggered on the entire remaining balance. It's not =n insurmountable problem, but it needs to be done right and Noam's =ttorneys and Harry's attorney and I need to be on the same page about =hatever settlement is worked out (and how it's documented) or we could =11 be in big trouble over taxes. > I =eally do hope that Noam can be prevailed upon to let his attorneys =peak with Harry's. I'm in the middle here and whether or not I'm =ued by anyone there won't be a settlement until the real "parties in =nterest" start communicating. > A. Max =ohlenberg > Howland Evangelista Kohlenberg Burnett, =LP > One Financial Plaza - Suite 1600 >=Providence, Rhode Island 02903 > Direct: = > Main: > Fax: > www.hekblaw.com > This email and any attachments thereto are intended only =or use by the addressee(s) named herein and may contain legally =rivileged and/or confidential information. If you are not the =ntended recipient of this email, you are hereby notified that any =issemination, distribution or copying of this email, and any =ttachments thereto, is strictly prohibited. If you have received =his email in error, please immediately notify me by return email and =ermanently delete the original and any copy of this message or =ttachment. Thank you. 2 EFTA_R1_01903749 EFTA02657508 > =----Original Message > From: Richard Kahn [mailto > Sent: =onday, May 21, 2018 3:29 PM > To: Max Kohlenberg > Subject: > max, > you were going to provide me proof of all the income =oing to noams account? thx > harry has =tated that there are legal issues preventing him from =iquidation NONSENSE > if I =ere you i would weigh in sooner rather than in another forum.. > Richard Kahn > HBRK Associates Inc. > 575 Lexington Avenue 4th Floor > New =ork, NY 10022 > tel > =ax > cell 3 EFTA_R1_01903750 EFTA02657509