EFTA02651698.pdf

From: jeffrey E. <[email protected]> Sent: Sunday, April 30, 2017 4:21 PM To: Brad Wechsler Cc: Tom Turrin; Barry Cohen; Leon Black Subject: Re: try to tie down other notices to other execs. =C2* either way torn is showing loss of approx 880,.=A0 and the irs a gain of the same amount. possible coincidence..=A0 my choice is to write the alternate letter with many edits.=C2*. detaling the fact that we have available all the records4>=A0 that tie to the return if she wants to review. =C2.3/ I would like an opinion from e and y, if this =quot; adjustment " means we will have to acknowldge in the futu=e an error on audit. ? I will consider the options=C2* but i am hesitant to admit a approx 1 million dollar mistake.=C240 with the concern of what it means for future years. .4F=A0 I m still very unclear of why it has taken so long to tie n=mbers. I am really only interested in the 54 m vs 53. O On Sun, Apr 30, 2017 at 11:33 AM, < > wrote: Guys-can I just mention an= confirm some things: 1. As an fyi, but as I believe you know, Ftl is pulling together the back-up=and presentation on the other items of BRH income highlighted in the origi=al IRS notice this week end. Hopefully we will not have to submit. 2. As we all know I aint no tax guy but I read the assessment letter very c=refully and my "uninformed" view is exactly torn and jeffrey'= first reaction (which may or may not have changed), ie, that the IRS4F=A0 found/acknowledges 378,805,695 of what they believe should be 379,707,3=1 or a delta of 884,006. (They also found a delta of 17,680 in itemized de=uctions.) Definitionally, these numbers have to include BRH numbers and as=jeffrey said to me, they answered the question they posed in the initial n=tice. 3. In that context, my personal view is that torn tries to reach out by phon= monday (after he and jeffrey touch base today or tomorrow morn to coordin=te) to confirm that the 360k assessment is the show stopper. 4. On a parallel basis, I'd have jeffrey and tom edit the "a=ternate response letter" which, again, would set out our belief=that the "assessment" ends this process, at least for 2012. If w= don't hear back from the agent then we should submit in writing our u=derstanding of the notice and assessment. 5. As an aside, if leon's brh assessment is 884,006 it wld be nice to s=e if that foots with the overall assessment to the other BRH partners and =ross-check to ownership %'s; although at the end of the day I'm no= certain that's critical. Thgts? I'm reachable by email or cell phone. Best, b Sent from my Verizon Wireless BlackBerry conversation-id 45882 date-last-viewed 0 date-received 1493569287 flags 8590195713 gmail-label-ids 7 6 remote-id 709624 EFTA_R1_01894058 EFTA02651698