Case File
efta-02398601DOJ Data Set 11OtherEFTA02398601
Date
Unknown
Source
DOJ Data Set 11
Reference
efta-02398601
Pages
4
Persons
0
Integrity
Extracted Text (OCR)
Text extracted via OCR from the original document. May contain errors from the scanning process.
From:
Barry J. Cohen
Sent:
Saturday, August 19, 2017 2:14 PM
To:
Jeff Epstein
Subject:
Fwd: Planning
> Apollo flight is one that qualifies for Apollo reimbursement and Apollo p=ys for.
> Pro forma depends on when Apollo gives us data. Hopefully very soon.
> Gift tax case wasn't "advice". Just a blurb Joe read in a publication. =e might well have got it wrong. It was just
something he thought he rememb=red and mentioned in passing. He was making the point that it might be a =ad idea
for a tax return to have info that is factually wrong even if the =ax is right. Whether the case exists or not, that advice
hardly seems craz=.
> Joe V is the best person we saw and is doing a great job. We have hired t=p lawyers and accountants. Always glad to
see better people but we are not=finding them. And very hard to find jacks of all trades. We tend to see n=rrow
expertise.
> S&C reviewed our estate planning and basically said everything we are doi=g is fine. EY reviewed our income tax
planning and has been helpful, but h=s not had great suggestions for changing anything.
> If you see specific things we should be doing differently let us know wha= they are. If you know of people who will
have greater insight than the on=s we are using, we are eager to talk to them.
> I too wish Leon would sell more art. We may have losses to partially off=et art gains. To the extent we do not, as you
have pointed out, getting a =tep up on death may be preferable for the pieces with gain. In any event, =e don't know if
Leon is willing to sell. So we cannot plan around that. My=goal is to be able to tell him "If you sell certain art you will
achieve t=e following benefits." Not quite there yet.
> On the CLATs, I hear you that no one has experience with art. But as you =ave pointed out, Leon's situation is unique.
Unless we hear specific reaso=s why it doesn't work it is hard to ignore the unanimous chorus of opinion= that it is a
sound planning tool.
> Sent from my iPhone
> On Aug 19, 2017, at 7:44 AM, jeffrey E. <[email protected]<mailto:[email protected]» wrote:
> what is an apollo flight . ? when will we have the proforma ? the=gift tax paid but still fraud fable is just that .
cant be found be=ause it doesnt exist. you are getting childish advice and data. ? sor=y. I was very clear with leon
that you need a senior tax advisor . per=on. Joe V is not it.
you have bookkeepers , accountants and enad =
compliance. you going around to others to see how they work is in my=opinion the height of silliness.
I consider
you tthe best thing that =appened to elysium . and have been quite vocal about it. hire the best =eople . they cost
money. This biz is leons most important asset that h= will leave to his kids.. It will be responsbile for a whole host of
fam=ly , estate. operating issues. .
> i have not gottten involved in the documentation , of what is there . =nd its acccesibility. i would guess pretty good
now.
For ex , my =isccusions with other clients are a give and take , of laws mecahnisms.=tactics strategys.. audit
prep. . case law.. a joint composition of=high level planning . reporting. analyisis, alternatives.
hearing=about an
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article that your guy might have read in his dentitst office. th=t turns out to be bogus. is emblematic of the office. I am
confient tha= you will grow into the job, . re clats I only asked if any of your s= called advisors have actually done one
so they understand its true and =pracitcal pitfalls.
your response that the art will be sold quickly. =and that there is a
chapter in lerners book about it , the same book that =eon relied on to his detriment before. ( 1031 ) . was suprising, .
if =he art is to be sold quickly ( not sure leon would sign on. ) , DO it =efore he dies. not after. art delays the closing
of the estate.
le=n is the "BEST seller. , know the market etc. gains can be dealt with =
> I real tax advisor should demand at least lm per year. up to 3 . al= the big firms have a mandatory retirement at
age 60. high level peopl= all on the street. my friends biz that only grosses 60 m just hired =ne for a million. guys
that have hand filled out PERSONAL tax returns =TRUST returns . planned strategies years in advance. . Audit
experienc= preferable large case. . some tax court experience helpful. . fille= out estate tax docs ( VERY IMPORTANT
> On Sat, Aug 19, 2017 at 7:20 AM, Barry J. Cohen <[email protected]<mail=o:[email protected]» wrote:
> Some trips for Apollo are not 135 compliant due to minor issues of crew r=st or otherwise. So occasionally we have to
fly Part 91 on Apollo flights.= Hard to do without Apollo being operator.
> Sent from my iPhone
» On Aug 18, 2017, at 10:57 PM, Jeffrey Epstein <[email protected]<mai=to:[email protected]» wrote:
» Apollo?
>» On Aug 18, 2017, at 10:56 PM, Barry J. Cohen <
wrote:
>»
>» We are factoring this into our structure recommendations. Lots of con=traints. Apollo doesn't want to be an owner
or an operator. Makes 91 opera=ions for Apollo tricky.
>»
>» Sent from my iPhone
>»
>» On Aug 18, 2017, at 8:23 PM, jeffrey E.
<[email protected]<mailto:[email protected]><mailto:jeevacation@gmailcom<mailto:jeevacation@gmail=
corn>» wrote:
>»
>» ex
>»
Forwarded message
>» From: Melanie Spinella
>»
>»
>» Date: Thu, May 21, 2015 at 2:54 PM
>» Subject: Plane
>» To: "jeffrey E."
>» [email protected]<mailto:[email protected]><m=ilto:jeevacat
>»
>»
>»
>» Jeffrey — Leon asked me to ask you. Debra is going to Chicago May
>» 30=h — back and forth the same day. Here is the response from Jet
>»
>» Hi Melanie,
>»
>» For May 30th with the 12pm departure out of Teterboro and 11pm departur= out of Chicago the duty day is at
15hrs18min. For 135 trips crew cannot e=ceed 14hr duty day. If you wish to operate this flight as 135 we must do
2
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a=crew swap in Chicago. If we were to operate this fight as 91 with a Chief =ilot approval we could extended the duty
day to 16hrs. Please let me know =ow you wish to proceed.
>»
>» Can we switch to 91— Here is what they said about the difference:
>»
>» When operation 91 the owner has operation control and we have a little =it of flexibility with extending the duty day
as long the chief pilot appr=ves it.
>» When operation 135 its consider business and the rules are a lot strict=r. We are not able to extend the duty day.
Two pilots can only be on duty =p to 14hrs and no more than 10hrs of flight time.
>» Thank you!
>»
>»
>»
>»
>»
>» Executive Assistant to Leon D. Black This email and any files
>» transmitted with it are confidential and inten=ed solely for the
>» person or entity to whom they are addressed and may cont=in
>» confidential and/or privileged material. Any review, retransmission,
>» di=semination or other use of, or taking of any action in reliance
>» upon this =nformation by persons or entities other than the intended
>» recipient is pro=ibited. If you have received this email in error
>» please contact the sender=and delete the material from any computer.
>» Apollo Global Management, LIC
>>>
>>>
>>>
>» --
>»
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@gmailcom<mailto:jeevacation@=mail.com><mailto:jeevacati
>» [email protected]<mailto:[email protected]», and destroy this
>» communication and all copies thereof, including all attachments.
>» copyright -all rights reserved This email and any files transmitted
>» with it are confidential and inten=ed solely for the person or
>» entity to whom they are addressed and may cont=in confidential
>» and/or privileged material. Any review, retransmission,
>» di=semination or other use of, or taking of any action in reliance
>» upon this =nformation by persons or entities other than the intended
>» recipient is pro=ibited. If you have received this email in error
>» please contact the sender=and delete the material from any computer.
>» Apollo Global Management, LLC
>»
> This email and any files transmitted with it are confidential and
3
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> intende= solely for the person or entity to whom they are addressed
> and may contai= confidential and/or privileged material. Any review,
> retransmission, diss=mination or other use of, or taking of any action
> in reliance upon this in=ormation by persons or entities other than
> the intended recipient is prohi=ited. If you have received this email
> in error please contact the sender a=d delete the material from any
> computer. Apollo Global Management, LLC
> --
>
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:jeevacation@gm=il.com>, and destroy this
> communication and all copies thereof, including all attachments.
> copyright -all rights reserved This email and any files transmitted
> with it are confidential and intende= solely for the person or entity
> to whom they are addressed and may contai= confidential and/or
> privileged material. Any review, retransmission, diss=mination or
> other use of, or taking of any action in reliance upon this
> in=ormation by persons or entities other than the intended recipient
> is prohi=ited. If you have received this email in error please contact
> the sender a=d delete the material from any computer. Apollo Global
> Management, LLC
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