EFTA02673495.pdf

From: Ada Clapp Sent: Monday, September 23, 2013 2:30 PM To: Jeffrey Epstein Cc: Alan S. Halperin; Eileen Alexanderson; Jessica Soojian Subject: Re: Petition for Advisory Opinion Attachments: DRAFT-Avisory Opinion Petition (9.23.13).docx; Untitled attachment 00356.htm Jeffrey, The form is set up so that you cannot save =t as a document in editable format. Whomever is representing your =lient and submitting the Petition on his, her or its behalf will either =eed to (i) print out the form and type in the information (using =n Attachment), or (ii) type most of the information into the form =nline and save it as a PDF document (the form is not flexible enough to =nclude the lengthly response to item 4, so your representative will =eed to use an Attachment). The PDF document can be printed and =ubmitted with the Attachment. I have =ttached what your client's representative may wish to use as responses =o items 1-4. Item S addresses =dditional redacting you may wish for your client if you include any =nformation other than what is on the attached draft =etition. Item 6 relates to reserving =our client's right to participate in New York's Voluntary Disclosure =nd Compliance program with respect to the subject of the advisory =pinion. As you may know, this program is designed to encourage =axpayers to come forward and declare unpaid taxes in exchange for NY =ot imposing penalties or bringing criminal charges. I do not know =f there is any downside to reserving the ability to participate in the =DC program-- but it would only apply to sales and use tax relating to =our client's having substituted tangible personal property into a =rantor trust in exchange for other property. If your client has =ot done this, perhaps it makes no sense to reserve this right. I =m not sure if it "looks suspicious" to check this box. Perhaps =Ian has a better feel for =his? Your representative =ill also need to fill out page 3 of the Petition which is the Power of =ttorney and make the required =eclaration. New York NY 10019 phone IRS Circular 230 =isclosure: Pursuant to IRS =egulations, I inform you that any tax advice contained in this =ommunication (including attachments) is not intended or written to be =sed, and cannot be used by any person or entity for the purpose of (i) =voiding tax related penalties imposed by any governmental tax =uthority, or (ii) promoting, marketing or recommending to another party =ny transaction or matter discussed herein. I advise you to consult with =n independent tax advisor on your particular tax =ircumstances. This communication, =nd any attachment, is for the intended recipient(s) only and may =ontain information that is privileged, confidential and/or proprietary =nbsp;If you are not the intended recipient, you are hereby notified =hat EFTA_R1_01950341 EFTA02673495 further dissemination of this communication and its attachments is =rohibited. Please delete all copies of this communication and its =nbsp;attachments and notify me immediately that you have received them =n error. = 2 EFTA_R1_01950342 EFTA02673496