EFTA02452148

From: jeffrey E. <[email protected]> Sent: Friday, August 26, 2016 11:11 AM To: Brad S Karp; Fenn, Patrick Subject: privleged I can do call with both of you anytime before 11.. s=lution is easy, the only question is how far back . =AO I have filed 8865 for leon since 13.. however they n=w appear to be inaccurate. but filed. statut=s running.. mark and josh, have open statut=s . -no filing however IRS has a policy not to go back beyond 6 yrs=C2 in general. . IRS program for just this purpose =C2 delinquent international disclosures. is easy. the only=quesiion I have is do josh and mark file 3 years or 6 years. = of course filed along with the explanation from accounting for rea=onableness. . if they file 3 yrs leon will not amend,=C2 if they file 6 leon will amend 10-12. I dont think the =inger pointing for apollo deloitte , PWC is useful. =AO =AO please note The information contained in this commu=ication is confidential, may be attorney-client privileged, may cons=itute inside information, and is intended only for the use of the addre=see. It is the property of JEE Unauthorized use, disclosure or copyi=g of this communication or any part thereof is strictly prohibited a=d may be unlawful. If you have received this communication in error, pl=ase notify us immediately by return e-mail or by e-mail to [email protected], a=d destroy this communication and all copies thereof, including all a=tachments. copyright -all rights reserved --001a114040b8ccalf3053af79109-- conversation-id 71206 date-last-viewed 0 date-received 1472209860 flags 8590195713 gmail-label-ids 7 6 remote-id 639158 1 EFTA_R1_01552237 EFTA02452148