EFTA02615783.pdf

From: jeffrey E. <[email protected]> Sent: Wednesday, September 20, 2017 11:24 AM To: Barry J. Cohen Subject: Re: Phaidon btw, they are really smart. . however in=no way proactive . On Wed, Sep 20, 2017 at 7:13 AM, Barry J. Cohen < <mailto » wrote: Happy New Year! Sent from my iPhone On Sep 19, 2017, at 11:03 PM, jeffrey E. <[email protected] <mailto:jeevacation@=mail.com> wrote: Its ok. Happy new year. Talk next week On Tue, Sep 19, 2017 at 9:11 PM Barry J. Cohen < <mailto >> wrote: 5-6 EY people have told us that they have experience with audits. =A0 I thought I gave you all the names before. <=1" l=will get you a list of everyone we talk to at every firm who has audit exp=rience! Sent from my iPhone On Sep 19, 2017, at 7:04 PM, jeffrey E. <[email protected] <mailtoijeevacation@g=ail.com» wrote: do they have names ???7,2IIIII On Tue, Sep 19, 2017 at 5:28 PM, Barry J. Cohen <mailto » wrote: Phaidon may be $30MM. EFTA_R1_01815685 EFTA02615783  You are consumed with audit experience! Some of =ur tax team (mostly EY) have it. Others less so. Sent from my iPhone On Sep 19, 2017, at 5:09 PM, jeffrey E. <[email protected] <mailto:jeevacation@g=ail.com» wrote: I actually dont care whether or not he agrees . I would as= that you merely inquire as to how many 1040 fed audits 1040 l=rge case or 10 40 wealth squad audits hes actually managed or partcipated =n. how much loss do you think you can generate this year with a phaidon transa=tion.? On Tue, Sep 19, 2017 at 4:29 PM, Barry J. Cohen =span><BCohen@el=slIc.com <mailto » wrote: He is agreeing with you on gift tax returns. =an't leave everything blank. From: Jeffrey E. [mailto:[email protected] Sent: Tuesday, September 19, 2017 4:25 PM To: Barry J. Cohen < <mailto:[email protected]» Subject: Re: 000's think about it, again, ask j=e how many 1040 audits he has done. . what size. h=w complex. when we file a grat, we cal=late the gift explicity at zero. . it =s the calculation of a gift minus the annuity. It is sim=le math. no more 2 minus ( 1+=) does not equal NONE On Tue, Sep 19, 2017 at 4:19 PM, Barry J. Cohen <=a target="_blank" <=a» wrote: Fair enough. From: jeffrey E. [mailto:[email protected] Sent: Tuesday, September 19, 2017 4:19 PM To: Barry J. Cohen < <mailto:[email protected]» Subject: Re: 000's 2 EFTA_R1_01815686 EFTA02615784  dumblIn ill, as i told you, =omputers dont read letters On Tue, Sep 19, 2017 at 4:15 PM, Barry J. Cohen <=a href="mailtollIIIIIIIIIIIIIIIIIIII' target="_blank" <=a» wrote: Sorry I misunderstood on the 000s. Gift tax r=turns have to report a number somewhere, so maybe statute doesn't =tart. But if you filed an income tax return for an entity with no income or expenses, Joe V assumes the statute would start. 1= any event, we don't file returns that way. As I said, we wo=ld say "None" where appropriate. From: Jeffrey E. [mailto:[email protected]] Sent: Tuesday, September 19, 2017 4:09 PM To: Barry J. Cohen < <mailto:[email protected]» Subject: Re: 000's i did not suggest you use the 000 method. =AO Im sorry but i dont have the time . do yo= think if you filed a gift tax return and left everything blank the =tatue would run? On Tue, Sep 19, 2017 at 4:03 PM, Barry J. Cohen <=a href="mailto ' target="_blank" <=a» wrote: John Cook at EY said they would not sign a return th=t uses the 000s method. They said that there are too many footing pr=blems. Numbers won't tie to K-ls, W-2s, 1099s, etc. Al=o, if you only use it on part of the return, the various numbers on the return would not match internally. He also pointed ou= that this method effectively truncates numbers; though I'm not su=e what rounding rules you use. E.g., 101,499 become 101? What =appens to the other $499? <https://maps.google.com/?q=445+Park+Avenue+Suite+1401 %0D+N=w+York,+NY+10022+%3Chttps://map s.google.com/?q%3D445%2BPark%2BAvenue%2BSui=e%2B1401%250D%2BNew%2BYork,%2BNY%2B10022%26entry%3 Dgmail%26source%3Dg%3E&a=p;entry=gmail&source=g> Joe V likes the idea of putting in 0's inste=d of blanks. He says he uses "none". He did no= understand why this would affect the statute of limitations. Barry J. Cohen =A0I Elysium Management,=LLC I 3 EFTA_R1_01815687 EFTA02615785  445 Park Avenue Suite 1401 <https://maps.google.comfiq=445+Park+Ave=ue+Suite+1401%0D+New+York,+NY+10022&entry=gmail&source=g> New York, NY 10022 <https://maps.google.com/?q=445+Park+Ave=ue+Suite+1401%0D+New+York,+NY+10022&entry=gmail&source=g> = Tel. (646) 589-0322 <tel:(646)%20589-0322> I Cell (917) 941-0270 del:(917)%20941-0270> bcohen@elysll=.com <mailto:bcohen=elysllc.com> please no=e The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please no=e The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by 4 EFTA_R1_01815688 EFTA02615786  return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please no=e The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA_R1_01815689 EFTA02615787  please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved =AO please note The information contained i= this communication is confidential, may be attorney-client privileged,=may constitute inside information, and is intended only for the use =f the addressee. It is the property of JEE Unauthorized use, disclos=re or copying of this communication or any part thereof is strictly pro=ibited and may be unlawful. If you have received this communication =n error, please notify us immediately by return e-mail or by e-mail to =a href="mailto:[email protected]" target="_blank">jeevacation@gmai=.com, and destroy this communication and all copies thereof, inc=uding all attachments. copyright -all rights reserved --94eb2c1163a0c1884305599d3620-- conversation-id 31027 date-last-viewed 0 date-received 1505906646 flags 8590195713 gmail-label-ids 7 6 remote-id 751822 6 EFTA_R1_01815690 EFTA02615788