EFTA01800570.pdf

From: Jean Luc Brunel < > Sent: Sunday, March 13, 2011 1:12 AM To: Jeffrey Epstein Subject: Answer from Tax Lawyer Forwarded Message From: Mark Zand Date: Fri, 11 Mar 2011 17:48:23 -0500 To: Jeff Fuller <a Cc: jeanluc brunel < Subject: RE: Urgent urgent Jeff, Typically an IRS lien is filed by IRS to protect their interests when money is owed to them by a taxpayer. The IRS always has the right to engage in enforced collection activity (i.e. - asset seizures, bank levies etc.). However, If there is a payment plan (a/k/a - Installment Agreement) in plac= then the lien just stays in the system until the terms of the installment agreement are satisfied and the taxes are paid in full. Once the taxes are paid in full the lien is typically released within approx. 30 days after satisfaction of the tax debt. As you know we have been in the process of working with an IRS agent in NY & attempting to negotiate a payment plan with NY and shortly will be doing the same with Miami now that all of its' returns have recently posted. Prior to replying to your email I obtained updated IRS transcripts for both NY & Miami as of today's date relating to the 1042 tax issue. With regard t= Miami all 1042 returns have now been posted and while there are balances du= for the years of 2004 thru 2007 the transcripts do not reflect that a federal tax lien has been filed on those years at this point. With regard NY all returns have been posted as well. There are outstanding balances due for the NY entity. IRS has not adjusted the figures yet for 04, 05, 06 & 07 so at this moment I do not know what the totals will be for those years. 08 shows paid in full and 09 shows paid in full as of 3/7/11. The only year that reflected a lien was 2009 which was entered on 11/19/10. Now that 09 i= paid in full we should expect to see a lien release on or around 4/7/11 for 09. That's not to say that tax liens will not be placed on any other year that has a balance due as in all likelihood one will be. Please let me know if you have any other questions at any time and I will a= usual continue to keep you posted. Mark J. Zand, C.P.A., C.F.S.T. 300 South Pine Island Road - #110 Plantation, Florida 33324 Tel - Fax - Email Visit our website at www.zandcpas.com/newsletter.php to learn how to avoid identity theft during this tax season EFTA_R1_00140266 EFTA01800570 CONFIDENTIALITY NOTICE: The information in this email may be confidential and/or privileged. This email is intended to be reviewed by only the individual or organization named above. If you are not the intended recipient or an authorized representative of the intended recipient, you ar= hereby notified that any review, dissemination or copying of this email and its attachments, if any, or the information contained herein is prohibited. If you have received this email in error, please immediately notify the sender by return email and delete this email from your system. TAX ADVICE NOTICE: Circular 230 Disclosure - Pursuant to recently-enacted U.S. Treasury Department Regulations, we are now required to advise you that, unless otherwise expressly indicated, any federal tax advice contained in this communication, including attachments and enclosures, is not intended or written to be used, and may not be used, for the purpose of (i) avoiding tax-related penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any tax-related matters addressed herein. • Please consider the environment before printing this message Mark, We have had a technical problem with our credit line renewal due to the liens from the IRS. The bank has found two liens and is warning Jean lucs friend who secures our line and we need to give him an update. My understanding is that the first lien is satisfied with our three large payments for the Ny office and there is the lien for Miami which is stayed until the 1065s were filed for a couple years which were not showing up. Now you tell me they are showing up so we should be able to proceed with payment plans for Miami when you here back from them and Ny as well when yo= here back. I know you have called them and we have been waiting to here. Please confirm this synopsis or correct me and expand on this with copy to Jean luc so we can be clear on where we stand and share this info with the necessary parties. I just need to know lien status basically. Thanks Jeff Sent from my iPad End of Forwarded Message <?xml version=.0" encoding=TF-8"?> <!DOCTYPE plist PUBLIC "-//Apple//DTD PLIST 1.0//EN" "http://www.apple.com/DTDs/PropertyList-1.0.dtd"> cplist version=.0"> <dict> <key>date-last-viewed</key> <integer>0</integer> <key>date-received</key> <integer>1299978760</integer> <key>flags</key> <integer>8590195713</integer> <key>gmail-label-ids</key> <array> <integer>22</integer> <integer>2</integer> </array> <key>remote-id</key> <string>141873</string> 2 EFTA_R1_00140267 EFTA01800571 </dict> </plist> 3 EFTA_R1_00140268 EFTA01800572