Text extracted via OCR from the original document. May contain errors from the scanning process.
From:
Thomas Turrin <
Sent:
Sunday, April 30, 2017 10:18 PM
To:
; Jeffrey Epstein; Barry Cohen
Cc:
Leon Black
Subject:
RE:
Please see my comments below in red.
Ori inal Messa e
From:
[mailto
<mailto:
> )
Cc: Leon Black
Subject:
Guys-can I just mention and confirm some things:
1. As an fyi, but as I believe you know, FtJ is pulling together the ba=k-up and presentation on the other items of BRH
income highlighted in the =riginal IRS notice this week end. Hopefully we will not have to submit.&nb=p; 2. As we all
know I aint no tax guy but I read the assessment letter v=ry carefully and my "uninformed" view is exactly tom and
jeffrey=s first reaction (which may or may not have changed), ie, that the IRS&nbs=; found/acknowledges 378,805,695
of what they believe should be 379,707,381 or a delta of 884,006. (They also found a del=a of 17,680 in itemized
deductions.) Definitionally, these numbers have to=include BRH numbers and as jeffrey said to me, they answered the
question =hey posed in the initial notice.
The "delta" in income is not a resu=t of an audit of Leon's tax return. The "delta :=21; is Leon's (BFP's) allocable share of
the adjustment=of BRH Holdings, LP ordinary income
as a result of an audit of the ta= return of BRH Holdings. The issue is on th= BRH partnership return.
Suzan=e Wong
(or someone at Apollo or Deloitte) should be able to
provide a copy of the IRS audit report explaini=g the adjustment of BRH. I will not be able to speak =o the agent about
BRH specifically since I am not the tax preparer of BRH.=/b>
When the IRS audits a partnership and makes an =djustment to the partnership's income or deductions, t=e IRS sends
adjustment notices to the partners such as the o=e received late Friday in which they indicate the specific partner's
allocable share of the partnership adju=tment. The IRS notice also computes the additional tax =nd interest (there was
no penalty) related to the adjustment of BRH income.
The delta in itemized deductions is strictly du= to the fact that Leon's gross income increased due to the audit
adj=stment of BRH Holdings, LP...no other reason.
There was no disallowance of Leon's deduc=ions claimed on his personal return. Total gross=income affects the
amount of miscellaneous itemized d=ductions subject to the
2% gross income limitation...so the =mount of miscellaneous itemized deductions decreased due to increase in in=ome.
..it's simple limitation calculation.<=div>
3. In that context, my personal view is that tom tries to reach out by=phone monday (after he and jeffrey touch base
today or tomorrow morn to co=rdinate) to confirm that the 360k assessment is the show stopper. &nb=p; Brad, I agree
with this approach. The 360 assess=ent as a result of the BRH audit in my opinion is the show stopper....=f Leon were to
sign off on </=iv>
EFTA_R1_01297435
EFTA02336791
adjustment and pay the assessment promptly, tha= is the end of this.
4. On a parallel basis, I'd have jeffrey and torn edit the "=lternate response letter" which, again, would set out our
belie= that the "assessment" ends this process, at least for 2012. If re don't hear back from the agent then we should
submit in writing our understanding of the notice and assessment. I believe (and so does=font color="red"> my partner
Lisa G=Idman) that this notice of adjustment of should "end the process".
I can call first thing Monday and confirm (if
the agent takes my c=Il). We can discuss=strategy first thing tomorrow.
S. As an aside, if leon's brh assessment is 884,006 it wld be nice to =ee if that foots with the overall assessment to the
other BRH partners and=cross-check to ownership %'s; although at the end of the day I'm not certa=n that's critical.
The audit report issued to BRH Holdings, LP wou=d disclose the reason for the adjustment. <=>lt would be interesting
to see whether the audit adjustment is proport=onal to the other founding partners, it should be.
Thgts? I'm reachable by email or cell phone. Best, b Sent from my Veri=on Wireless BlackBerry
<https://staticl.squarespace.com/static/58933ee8cS34a53f8211=235/S8eba912f7e0ab8357051777/58ebafbbb8a79677
4ad68edb/1491841737642/REM-ne=logo_SM.png>
chttps://staticl.squarespace.com/static/58933eac=34a53f82110235/58eba912f7e0ab8357051777/58ebafbc17bffc10a
3c1a8fe/149184173=660/PrimeGlobal_color_blktext_TAGLINE.jpg>
<https://staticl.squarespace.com/static/58933eac534a53f82110235=58eba912f7e0ab835705f777/58ebb1772e69cf 27
721f6145/1491841737655/2016_IPA-1=0_WEB-147x150.png>
CONFIDENTIALITY STATEMENT: rr/b>The information contained in this electronic comm=nication, including any and all
attachments and enclosures, may be privileged and is strictly confidential, intended so=ely for the use of the person(s)
identified above to receive this communic=tion. If you are not the person(s) identified above to receive this
commun=cation, you are hereby notified that you may not disclose print, copy, disseminate, or otherwise use the
in=ormation contained herein. If you are an employee or agent of the person(s= identified above to receive this
communication and, as such, you have bee= authorized to deliver this communication to such person(s), you may
disclose, print, copy, disseminate, or otherwise=use the information contained in this communication solely for the
purpose=of such delivery. Unauthorized interception and/or use of this communicati=n are/is strictly prohibited and
may be punishable by law. If you have received this communication in error,=please reply and notify the sender (only) of
that fact and delete the comm=nication, including any and all attachments and enclosures, from your comp=ter or other
electronic device on which you may have received this communication.
2
EFTA_R1_01297436
EFTA02336792