EFTA02618887.pdf

From: jeffrey E. <[email protected]> Sent: Tuesday, September 19, 2017 9:09 PM To: Barry J. Cohen Subject: Re: 000's I actually dont care whether or not he agrees . =C2 I would ask that you merely inquire as to how many 1040 fed audits=C2 1040 large case or 10 40 wealth squad audits hes actually mana=ed or partcipated in. how much loss =o you think you can generate this year with a phaidon transaction.? On Tue, Sep 19= 2017 at 4:29 PM, Barry J. Cohen < <mailto » wrot=: 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 >> 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, Se 19, 2017 at 4:19 PM, Barry J. Cohen <=a href="mailto 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 >> Subject: Re: 000's dumb!InIII, as i told you, =omputers dont read letters EFTA_R1_01823118 EFTA02618887  On Tue, Sep 19, 2017 at 4:15 PM, Barry J. Cohen <=a href="mailto ' 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 start. But if you filed an income tax return for an entity with no i=come or expenses, Joe V assumes the statute would start. In any even=, we don't file returns that way. As I said, we would say =E2 None" where appropriate. From: jeffrey E. [mailto:[email protected] Sent: Tuesday, September 19, 2017 4:09 PM To: Barry J. Cohen < <mailto 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-1s, W-2s, 1099s, etc. Also, if you only use it on part of the return, the various numbers on the=return would not match internally. He also pointed out that this met=od effectively truncates numbers; though I'm not sure what roundin= rules you use. E.g., 101,499 become 101? What happens to the other $499? 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 445 Park Avenue Suite 1401 <https://maps.google.com/?q=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. 2 EFTA_R1_01823119 EFTA02618888  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 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 3 EFTA_R1_01823120 EFTA02618889  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">[email protected], and destroy this communication and all copies thereof, inc=uding all attachments. copyright -all rights reserved --001a1146e3d635bafa0559914673-- conversation-id 31149 date-last-viewed 0 date-received 1505855366 flags 8590195713 gmail-label-ids 7 remote-id 751404 4 EFTA_R1_01823121 EFTA02618890