EFTA02702930.pdf

From: Halperin, Alan S == Sent: Tuesday, May 10, 2016 4:11 PM To: Thomas Turrin; jeffrey E. Subject: RE: GIFT TAX AUDIT Thanks. I am working o= a proposed response to the IRS letter. Could you tell me how the gift amo=nt relating to the split dollar insurance arrangement was determined and s=nd me the supporting document? Alan Alan S. Halperin</=pan> I Partner Paul, Weiss, Rifkind, Wharton & Garrison LIP 1285 Avenue of the Americas I New York, NY 10019-6064 www.paulweiss.com <http: www.pau weiss.com> From: Thomas Turrin Sent: Tuesday, May 10, 2016 10:48 AM To: jeffrey E. <[email protected]>; Halperin, Alan S Subject: GIFT TAX AUDIT Alan and Jeffrey, The agent finally called me this morning. = He was apologetic that he didn't call sooner. He said hec;s been in and out of the office the last couple of weeks.</=> He was very nice on the phone....saying we can h=ve more time to get him the information requested. However, he said to contact him by the end of May if=we still need more time. He said he would grant more time, if necessary. I would hope we can get the response done as soon as=possible so we don't have to ask for more time. EFTA_R1_02077108 EFTA02702930 The bad news is that they will also examine 2014.&nb=p; He told me a letter will go out soon. Mr. Falk readily volunteered that it is the GRATS (s=ecifically the valuations) that are kicking off the audits. He did say that he would try to "move the audi=s along".... He also said he sees (and audits) valuations from Empire all the time. I'm reachable all day, if you would like to ca=l. Tom THOMAS TURRIN, CPA Partner Raich Ende Malter & Co. LLP 1375 Broadway<=o:p> New York, New York =0018 ext 2=04) Dire=t line) Fax)=o:p> Cell= Email Website: www.rem-co.com 2 EFTA_R1_02077109 EFTA02702931  &n=sp; &=bsp; CONFIDENTIALITY STATEMENT: The information contained in this electronic communication, including any and all attachments and enclo=ures, may be privileged and is strictly confidential, intended solely for =he use of the person(s) identified above to receive this communication. If=you are not the person(s) identified above to receive this communication, you are hereby notified that you may =ot disclose print, copy, disseminate, or otherwise use the information con=ained herein. If you are an employee or agent of the person(s) identified =bove to receive this communication and, as such, you have been authorized to deliver this communication to su=h person(s), you may disclose, print, copy, disseminate, or otherwise use =he information contained in this communication solely for the purpose of s=ch delivery. Unauthorized interception and/or use of this communication are/is strictly prohibited and may be pun=shable by law. If you have received this communication in error, please re=ly and notify the sender (only) of that fact and delete the communication,=including any and all attachments and enclosures, from your computer or other electronic device on which you=may have received this communication. This message is intended only fo= the use of the Addressee and may contain information that is privileged a=d confidential. If you are not the intended recipient, you are hereby not=fied that any dissemination of this communication is strictly prohibited. =If you have received this communication in error, please erase all copies =f the message and its attachments and notify us immediately. 3 EFTA_R1_02077110 EFTA02702932