EFTA02613282.pdf

From: Barry J. Cohen Sent: Wednesday, September 20, 2017 11:27 AM To: jeffrey E. Subject: Re: Phaidon Our experience too. Sent from my iPhone On Sep 20, 2017, at 7:24 AM, jeffrey E. <[email protected] <mailto:jeevacation@g=ail.com> wrote: btw, they are really smart. . however in=no way proactive . • Barry J. Cohen =span dir="ltr" Happy New Year! Sent from my iPhone On Sep 19, 2017, at 11:03 PM, jeffrey E. <[email protected] <mailto:jeevacation@=mail.com» wrote: Its ok. Happy new year. Talk next week 7 at 9:11 P 5-6 EY people have told us that they have experience with audits. = I thought I gave you all the names before. <=r> i=WilI get you a list of everyone we talk to at every firm who has audit exp=rience! Sent from my iPhone On Sep 19, 2017, at 7:04 PM, jeffrey E. <[email protected] <mailto:jeevacation@g=ail.com> wrote: EFTA_R1_01810547 EFTA02613282  do they have names On Tue, Sep 19, 2017 at 5:28 PM, Barry J. Cohen =span> <mailt ote: Phaidon may be $30MM. You are consumed with audit experience! Some of our tax team (mostly =Y) have it. Others less so. Sent from my iPhone On Sep 19, 2017, at 5:09 PM, jeffrey E. <[email protected] <mailto:jeevacation@g=ail.com» wrote: I actually dont care whether or not he agrees . I would as= that you merely inquire as to how many 1040 fed audits 1040 l=rge case or 10 40 wealth squad audits hes actually managed or partcipated =n. how much loss do you think you can generate this year with a phaidon transa=tion.? On Tue, Sep 19, 2017 at 4:29 PM, Barry J. Cohen =span> <mailt wrote: He is agreeing with you on gift tax returns. =an't leave everything blank. From: Jeffrey E. [mailto:[email protected] Sent: Tuesday, Sept • To: Barry J. Cohen < 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&=43;1) does not equal NONE n Tue, Se • <=a href="mailto:B t="_blank" 2 EFTA_R1_01810548 EFTA02613283  Fair enough. From: Jeffrey E. [mailto:[email protected] Sent: Tuesday, Se - To: Barry J. Cohen Subject: Re: 000's dumbl nu 1I, as i told you, =omputers dont read letters On Tue, Sep 19, 2017 at 4:15 PM, Barry!. Cohen <=a href="mailto:[email protected]" target="_blank">[email protected]<=a» wrote: Sorry I misunderstood on the 000s. Gift tax r=turns have to report a number somewhere, so maybe statute doesn't start.=nbsp; But if you filed an income tax return for an entity with no income or expenses, Joe V assumes the statute would start. 1= any event, we don't file returns that way. As I said, we would sa= "None" where appropriate. From: Jeffrey E. [mailto:[email protected] Sent: Tuesday, Septiiii To: Barry J. Cohen Subject: Re: 000's i did not suggest you use the 000 method. = Im sorry but i dont have the time . do you =hink if you filed a gift tax return and left everything blank the st=tue would run? href="r iliMMIONIM 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-ls, 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 ou= that this method effectively truncates numbers; though I'm not sure wha= rounding rules you use. E.g., 101,499 become 101? What happen= to the other $499? chttps://maps.google.com/?q=445+Park+Avenue+Suite&ff=3;1401 %0D+New+York,+NY+10022+%3Chttps:/ /maps.googl=.com/?q%3D445%2BPark%2BAvenue%2BSuite%2B1401%250D%2BNew%2BYork,%2BNY%2B100=2%26ent ry%3Dgmail%26source%3Dg%3E&entry=gmail&source=g> 3 EFTA_R1_01810549 EFTA02613284  Joe V likes the idea of putting in 0's instead of =lanks. He says he uses "none". He did not understand why t=is would affect the statute of limitations. Barry J. Cohen = I Elysium Management,=LLC I 445 Park Avenue Suite 1401 <https://maps.google.comfiq=445+Park=t143;Avenue+Suite+1401%0D+New+York,+NY+10022&en=ry=gmail&source=g> New York, NY 10022 <https://maps.google.com/?q=445+Park=tf43;Avenue+Suite+1401%0D+New+York,+NY+10022&en=ry=gmail&source=g> Tel. (646) 589-0322 <tel:(646)%20589-0322> I Cell (917) 941-0270 <tel:(917)%20941-0270> bcohen@elysll=.com <mailto:bcohen=elyslIc.com> 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 4 EFTA_R1_01810550 EFTA02613285  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 note 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 5 EFTA_R1_01810551 EFTA02613286  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 note 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 note 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 note 6 EFTA_R1_01810552 EFTA02613287 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 7 EFTA_R1_01810553 EFTA02613288