EFTA00859395.pdf

From: Heather Gray To: "Jeffrey Epstein [email protected] <[email protected]> CC: Brad Wechsler >, Richard Joslin Subject: question re: possible 1031 Date: Wed, 15 Apr 2015 13:33:53 +0000 Good morning, Jeffrey, Narrows Holdings LLC is consigning a Calder mobile to Christie's for their May 11th Looking Forward to the Past sale. Leon bought the Calder from PaceWildenstein in 2009 for $3,758,125 (including NY sales tax) and transferred it to Narrows as part of the 2012 contribution of all art to Narrows that Ralph prepared. Christie's is giving Narrows a guarantee of $6.5 million, plus 80% of any overage (the amount of the hammer price above $6.5 million). Should we try to structure this sale as a possible 1031exchange? We have to sign the Christie's consignment agreement today because they are at their publication deadline, but I can include a provision in the consignment agreement that allows us to assign the agreement to a qualified intermediary if you think we might want to do a 1031. If we decide to move forward, we would need to decide who to use as QI (an art dealer or a corporate QI), and Leon would need to identify within 45 days of the auction art that he might want to acquire. The only things I have heard about that he may be buying are some Old Master drawings coming from Europe, so those would not work for the exchange, but the big Impressionist and Contemporary sales are the first two weeks in May, so there may be things in those sales that he is interested in. I have not previously done a 1031 with a single-member LLC, but I can't see any reason why it wouldn't work, and we have outside tax counsel that I'll ask to weigh in and work on the exchange if you want to take this forward. I'm in the office and happy to discuss (at Best, Heather Heather Gray Elysium Management LLC Direct Dial: Fax: Email: EFTA00859395