EFTA02366456

From: Barry J. Cohen Sent: Tuesday, September 19, 2017 9:29 PM To: Jeffrey E. Subject: Phaidon Phaidon may be $30MM. You are consumed with audit experience! &nbs=;Some of our tax team (mostly EY) have it. Others less so. Sent from my iPhone On Sep 19, 2017, at 5:09 PM, jeffrey E. <jeevacation@gmail.com <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.? <mailt On Tue, Sep 19, 2017 at 4:29 PM, Barry J. Cohen =span dir="ltr" .=om > wrote: He is agreeing with you on gift tax returns. =an't leave everything blank. From: jeffrey E. [mailto:jeevacation@gmail.com] Sent: Tuesday, Se • To: Barry J. Cohe 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 On 4:19 PM, Barry J. Cohen as href=" target="_blank"> » wrote: Fair enough. EFTA_R1_01363063 EFTA02366456 From: Jeffrey E. [mailtoleevacation@gmail.comj Sent: Tuesday, September 19 2017 4:19 PM To: Barry J. Cohen Subject: Re: 000's dumbl I HI ll, as i told you, =omputers dont read letters On Tue, Se 19, 2017 at 4:15 PM, Barry J. Cohen <=a target="_blan » 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:jeevacation@gmail.com] Sent: Tuesday, September 19, 2017 4:09 PM 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? On Tue, Sep 19, 2017 at 4:03 PM, Barry J. Cohe target="_blank"SilaiS wrote: 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? 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 2 EFTA_R1_01363064 EFTA02366457 Elysium Management,=LLC I <https://maps.google. <https://maps.google. privileged, may and privileged, may 445 Park Avenue Suite 1401 com/?q=445+Park=#43;Avenue+Suite+1401%0D+New+York,+NY+10022&en=ry=gmail&source=g> New York, NY 10022 com/?q=445+Park=t143;Avenue+Suite+1401%0D+New+York,+NY+10022&en=ry=gmail&source=g> please no=e The information contained in this communication is confidential, may be attorney-client 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 jeevacation@gmail.com <mailto:jeevacation@gmail.com> , 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 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 3 EFTA_R1_01363065 EFTA02366458 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 jeevacation@gmail.com <mailto:jeevacation@gmail.com> , 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 jeevacation@gmail.com <mailto:jeevacation@gmail.com> , 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 jeevacation@gmail.com <mailto:jeevacation@gmail.com> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved 4 EFTA_R1_01363066 EFTA02366459