EFTA02651245.pdf

From: jeffrey E. <[email protected]> Sent: Sunday, April 30, 2017 10:51 PM To: Barry Cohen; Thomas Turrin; [email protected] Cc: Leon Black Subject: Re: We were told that neither Deloitte or apollo tax knew of this . That w=s the first question On Sun, Apr 30, 2017 at 6:18 PM Thomas Turrin <[email protected]> wrote: Please see my comments below in red. <=iv> Original Message From: > [mailto:[email protected] <mailto: Sent: Sunday, April 30, 2017 11:33 AM To: Jeffrey Epstein; Thomas Turrin; Barry Cohen Cc: Leon Black Subject: Guys-can I just mention and confirm some things: 1. As an fyi, but as I believe you know, RJ is pulling together the ba=k-up and presentation on the other items of BRH income highlighted in the =riginal IRS notice this week end. Hopefully we will not have to submit. =A0 2. As we all know I aint no tax guy but I read the assessment letter v=ry carefully and my "uninformed" view is exactly tom and jeffrey=1439;s first reaction (which may or may not have changed), ie, that the IRS=C2 found/acknowledges 378,805,695 of what they believe should be 379,707,381 or a delta of 884,006. (They also found a del=a of 17,680 in itemized deductions.) Definitionally, these numbers have to=include BRH numbers and as jeffrey said to me, they answered the question =hey posed in the initial notice. The "delta" in i=come is not a result of an audit of Leon's tax return. =AO The "delta" is Leon's (BFP's) al=ocable share of the adjustment of BRH Holdings, LP ordinary =ncome as a result of an audit of the ta= return of BRH Holdings. The issue is on th= BRH partnership return. Suzan=e Wong (or someone at Apollo or Deloitte) should be able to provide a copy of the IRS audit report explaini=g the adjustment of BRH. I will not be able to speak =o the agent about BRH specifically since I am not the tax preparer of BRH.=/b> When the IRS audits a partnership and makes an =djustment to the partnership's income or deductions,=the IRS sends adjustment notices to the partners such as the=one received late Friday in which they indicate the specific partner's allocable share of the partnership ad=ustment. The IRS notice also computes the additional ta= and interest (there was no penalty) related to the adjustment of <=b>BRH income. The delta in itemized deductions is strictly du= to the fact that Leon's gross income increased due to the audit a=justment of BRH Holdings, LP...no other reason. There was no disallowance of Leon's ded=ctions claimed on his personal return. Total gro=s income affects the amount of miscellaneous itemized=deductions subject to the EFTA_R1_01892633 EFTA02651245 2% gross income limitation...so th= amount of miscellaneous itemized deductions decreased due to increase in =ncome. ..it's simple limitation calculation. 3. In that context, my personal view is that torn tries to reach out by=phone monday (after he and jeffrey touch base today or tomorrow morn to co=rdinate) to confirm that the 360k assessment is the show stopper. =AO Brad, I agree with this approach. The 360 assess=ent as a result of the BRH audit in my opinion is the show stopper =A6.if Leon were to sign off on adjustment and pay the assessment promptly, tha= is the end of this. 4. On a parallel basis, I'd have jeffrey and tom edit the &q=ot;alternate response letter" which, again, would set out our b=lief that the "assessment" ends this process, at least for 2012.=If we don't hear back from the agent then we should submit in writing our understanding of the notice and assessment. I believe (and so does=font color="red"> my partner Lisa G=ldman) that this notice of adjustment of should "end the process". I can call <=ont color="red">first thing Monday and confirm (if the agent takes my=call). We can discu=s strategy first thing tomorrow. <=iv> 5. As an aside, if leon's brh assessment is 884,006 it wld be nice=to see if that foots with the overall assessment to the other BRH partners=and cross-check to ownership %'s; although at the end of the day I'=m not certain that's critical. The audit report issued to BRH H=ldings, LP would disclose the reason for the adjustment. =b> It would be interesting to see whether the audit adjust=ent is proportional to the other founding partners, it should be. Thgts? I'm reachable by email or cell phone. Best, b Sent from my =erizon Wireless BlackBerry <https://ci3.googleusercontent.com/proxy/Qvu=c1_5799uoloGlagTOuzalKYJRNnX7C8ra6t5X5b17CGZD2rI2EAif3- b85qiWRAZrlOmsioSuzI=Dm6Lyb5mk8U8jYYVvAQALn53iXskD5c8FdPX-2xmNqYqtVO.iMb0260s5R62hjU-3GsX4bv_p- O=UsFwlEu0eEITTh_lafa0wYQ9puUBMtKGFFOODctlQZMjQr8AwPjuurhlK-kKt9denpmneCBQ=30s0-d-el- ft#https://staticl.squarespace.com/static/58933ee8c534a53f821102=5/58eba912f7e0ab835705f777/58ebafbbb8a7967 74ad68edb/1491841737642/REM-newl=go_SM.png> <https://ci5.googleusercontent.com/proxy/M_LRKaVgl8=7QPsI8N5QFvlOmWODovhVCEN0.19vYmCHBEyFycSxMQ6xsyndl Yj9FL5oG-NIZs2CPRAc6YFHYf4=X3G071AoB47PIrcIpREDnVzIreUasMrDu4GPbYhNq5vndXDISIHOzwN- Sm LO9UIS_HANucrONS=31QZAjm5xkvAF1i6a8ayzDU2lHfr4HzuWXNkxYQAqIrkYl119N_a3Dfro5PHunFpElBxN9bQZG=trEc lf_TzjaBG8U=s0-d-el- fttfhttps://static1.squarespace.com/static/58933e=8c534a53f82110235/58eba91217e0ab835705f777/58ebafbc17bffc10 a3c1a8fe/149184=737660/PrimeGlobal_color_blktext_TAGLINE.jpg> <https://ci4.googleusercontent.com/proxy/GoHW4q8e6I6GuVDpHRipMaT=OCIltI4BTLXqsdjfosggyVzBx_EWHCtn_3EHD 560XiMgBUsByR9ir8ftFq5Ex5ieCdTMrpVSLO=jloE2KOtoBPBdjjUwqEQUEBr54a5ngs6eQBUYTmoxGGjoHAEi4HpNrg2pQ71 NnWw6CyC8I2vWM=if9ORIBIAvDwyHc3kInKoTtgkqHQQweMyZPInl MemGMXnQKYInAPkIZ9h8_57-To0=s0-d-e=- ft#https://staticl.squarespace.com/static/58933ee8c534a53f82110235/58eba9=217e0ab835705f777/58ebb1772e69cf2 7721f6145/1491841737655/2016iPA-100_WEB-=47x150.png> CONFIDENTIALITY STATEMENT: </=>The information contained in this electronic commun=cation, including any and all attachments and enclosures, may be privileged and is strictly confidential, intended so=ely for the use of the person(s) identified above to receive this communic=tion. 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