EFTA02508229

From: jeffrey E. <[email protected]> Sent: Monday, March 9, 2015 5:01 PM To: Melanie Spinella Subject: Fwd: FW: Ben's 2012 Gift Tax Return Tweedle dum and dee still in loop -Forwarded message From: Ada Clapp < Date: Monday, Marc Subject: FW: Ben's 2012 Gift Tax Return To: "jeffrey E=" <jeevacation mail.com<=a» Cc: Brad Wechsler < FYI </=pan> </=pan> From: Ada Clapp Sent: Monday, March 09, 2015 12:03 PM To: Thomas Turrin; Richard loslin Cc: Halperin, Alan 5; Brad Wechsler; Eileen Alexanderson Subject: RE: Ben's 2012 Gift Tax Return Michael Shenker called=Alan today in connection with the IRS's audit of Ben's gif= tax return. Michael wanted Alan to confirm for him that he understo=d the facts surrounding the Note and the gift. After Alan did so, Michael indicated that he wanted to think about it further but was=inclined toward a "no change" determination. </=pan> Alan will keep us post=d if he hears anything further. We would appreciate it if you would =o the same. </=pan> Thanks!<=span> </=pan> Ada Clapp=/u> Chief Legal Officer=/u> EFTA_R1_01639192 EFTA02508229 </=pan> Elysium Management LLC=u> 445 Park Avenue=u> Suite 1401</=> New York, New York 100=2 vascript:_e(%7B%7D,'cvml ');=. target=> =/u> This communication =nd any attachment is for the intended recipient(s) only and may contain in=ormation that is privileged, confidential and/or proprietary. If you are not the intended recipient, you are hereby notified that further dissemina=ion of this communication and its attachments is prohibited. Please =elete all copies of this communication and its attachments and notify me i=mediately that you have received them in error. Thank you. </=pan> </=pan> From: Thomas Turrin (ma=ltc ');> Sent: Wednesday, February 04, 2015 6:40 PM To: Ada Clapp Cc: Halperin, Alan S; Richard Joslin; Eileen Alexanderson; Brad Wech=ler Subject: Re: Ben's 2012 Gift Tax Return I agree...I normally let them get =ack to me. If we had not responded, he most likely would have =ontacted me. Sent from my Verizon Wireless 4= LTE DROID Ada Clapp <[email protected] <javascript:_e(%7B%7D;cvmr,'[email protected]');» wrote: No need (unless you th=nk it advantageous to do so). Just wondered. Thanks. Ada Clapp 2 EFTA_R1_01639193 EFTA02508230 Chief Legal Officer Elysium Management LLC=/span> 445 Park Avenue=u> Suite 1401</=> New York, New York 100=2 avascript:_e(%7B%7D;cvmr, ');= target=> This communication =nd any attachment is for the intended recipient(s) only and may contain in=ormation that is privileged, confidential and/or proprietary. If you are not the intended recipient, you are hereby notified that further dissemina=ion of this communication and its attachments is prohibited. Please =elete all copies of this communication and its attachments and notify me i=mediately that you have received them in error. Thank you. From: Thomas Turrin (ma=lto Sent: Wednesday, February 04, 2015 6:20 PM To: Ada Clapp Cc: Halperin, Alan 5; Richard Joslin; Eileen Alexanderson; Brad Wech=ler Subject: RE: Ben's 2012 Gift Tax Return Ada,<=u> I have not heard from =he agent. I will follow up tomor=ow. Tom</=> 3 EFTA_R1_01639194 EFTA02508231 THOMAS TURRIN, CPA Partner Raich Ende Malter & Co. LLP 1375 Broadway New York, New York =0018 Email: Website: www.rem-co.com <http://www.rem-co.com> From: Ada Clapp Imailto:[email protected] Sent: Wednesday, February 04, 2015 6:12 PM To: Thomas Turrin Cc: Halperin, Alan S; Richard Joslin; Eileen Alexanderson; Brad Wech=ler Subject: RE: Ben's 2012 Gift Tax Return Hi Tom,<=> Hope you are well. =AO Any response from the auditor? 4 EFTA_R1_01639195 EFTA02508232 Ada Clapp Chief Legal Officer Elysium Management LLC=/span> 445 Park Avenue=u> Suite 1401</=> New York, New York 100=2 <javascript:_e(%76%7D,lcvmP, ');= target=> This communication =nd any attachment is for the intended recipient(s) only and may contain in=ormation that is privileged, confidential and/or proprietary. If you are not the intended recipient, you are hereby notified that further dissemina=ion of this communication and its attachments is prohibited. Please =elete all copies of this communication and its attachments and notify me i=mediately that you have received them in error. Thank you. From: Thomas Turrin [ma=lto Sent: Thursday, January 08, 2015 12:49 PM To: Ada Clapp Cc: Halperin, Alan 5; Richard Joslin; Eileen Alexanderson Subject: RE: Ben's 2012 Gift Tax Return Ada,<=u> Attached is copy of co=plete response — the original is being mailed today via<=u> certified mail. =C2 The password to the pd= is my office zip code. ..below. >] 5 EFTA_R1_01639196 EFTA02508233 Tom</=> THOMAS TURRIN, CPA Partner Raich Ende Malter & Co. LLP 1375 Broadway New York, New York =0018 Email: Website: www.rem-co.com <http://www.rem-co.com> From: Ada Clapp [mailtri l Sent: Thursday, January 08, 2015 11:08 AM To: Thomas Turrin Cc: Halperin, Alan S; Richard Joslin; Eileen Alexanderson Subject: RE: Ben's 2012 Gift Tax Return Thank you!</=> Ada Clapp 6 EFTA_R1_01639197 EFTA02508234 Chief Legal Officer Elysium Management LLC=/span> 445 Park Avenue=u> Suite 1401</=> New York, New York 100=2 javascript:_e(%7B%7D;cvmr, );= target=> This communication =nd any attachment is for the intended recipient(s) only and may contain in=ormation that is privileged, confidential and/or proprietary. If you are not the intended recipient, you are hereby notified that further dissemina=ion of this communication and its attachments is prohibited. Please =elete all copies of this communication and its attachments and notify me i=mediately that you have received them in error. Thank you. From: Thomas Turrin (ma=lto Sent: Thursday, January 08, 2015 10:56 AM To: Ada Clapp Cc: Halperin, Alan 5; Richard Joslin; Eileen Alexanderson Subject: RE: Ben's 2012 Gift Tax Return Ada,<=u> I think the response i= fine as is. Will include cc to Ben on letter. Rich is sending POA to=ay...just got his email. I will forward complet= copy to you for your file. Tom</=> THOMAS TURRIN, CPA 7 EFTA_R1_01639198 EFTA02508235 Partner Raich Ende Malter & Co. LLP 1375 Broadway New York, New York =0018 • an> <javascript:_e(%7B%7D,'cvml' Website: www.rem-co.com <http://www.rem-co.com> From: Ada Clapp [mailtnill.la Sent: Thursday, January 08, 2015 10:48 AM To: Thomas Turrin Cc: Halperin, Alan 5; Richard Joslin; Eileen Alexanderson Subject: RE: Ben's 2012 Gift Tax Return Hi Tom,<=> #39;);> Just checking in to se= if you would like any changes to the audit response letter (as a reminder= I am out next week). Also, would you kindly add Ben as a "c=" to the letter. I would be grateful if you would also send me a copy of the final letter, with attachments for our files.=C2 Do you now have the Fo=m 2848? 8 EFTA_R1_01639199 EFTA02508236 Best regards, Ada Clapp Chief Legal Officer Elysium Management LLC=/span> 445 Park Avenue=u> Suite 14014=> New York, New York 100=2 ascript:_e(%7B%7D,'cvmr, );= target=> This communication =nd any attachment is for the intended recipient(s) only and may contain in=ormation that is privileged, confidential and/or proprietary. If you are not the intended recipient, you are hereby notified that further dissemina=ion of this communication and its attachments is prohibited. Please =elete all copies of this communication and its attachments and notify me i=mediately that you have received them in error. Thank you. From: Ada Clapp Sent: Tuesday, January 06, 2015 11:09 AM To: CPA Thomas Turrin ([email protected] <javascript:_e(%78%7D,scvml'=,[email protected].);> )=br> Cc: Halperin, Alan S Subject: Ben's 2012 Gift Tax Return Importance: High Hi Tom, Happy new year! We haven't spoken in a=while and I hope that you have been well. 9 EFTA_R1_01639200 EFTA02508237 I just left you a voicemail regarding the audit of B=n's 2012 Gift Tax Return. Attached is a proposed response to=Michael Shenker's most recent request for information. As yo= know, our reply is due by January 15th. Alan and I prepared the attached letter for your signature=(that is, if you approve of it, of course). As you can see, the prop=sed reply is as brief as possible while still being responsive to Mr. Shenker's requests. Given the comple= series of steps involved in the issuance of the $5.12 million note, Alan =nd I are pretty certain Shenker will have additional questions and ask for=additional documents. I just wanted to be sure that you were familiar with all the background. I am available =his week (but out of the country all next week), should you wish to discus= or to have me make changes to the letter. In my absence, please spe=k with Alan. Rich J. is getting Ben to sign the IRS power of atto=ney in favor of you and Alan. I assume you will need to send that with the attached letter, so I h=ve referenced it therein. Please follow up with Rich to obtain=he 2848. Thanks! Ada Clapp Chief Legal Officer Elysium Management LLC 445 Park Avenue Suite 1401 New York, New York 10022 "avascript:_e(%7B%7D,Icv=r, 1)7 This communication and any attachment is for the =ntended recipient(s) only and may contain information that is privileged, =onfidential and/or proprietary. If you are not the intended reci=ient, you are hereby notified that further dissemination of this communication and its attachments is prohibited. =AO Please delete all copies of this communication and its attachments and =otify me immediately that you have received them in error. Thank you= 10 EFTA_R1_01639201 EFTA02508238 =C2 =C2 CONFIDENTIALITY STATEMENT: The information contained in this electronic communication, including any and all attachments and enclo=ures, may be privileged and is strictly confidential, intended solely for =he use of the person(s) identified above to receive this communication. If=you are not the person(s) identified above to receive this communication, you are hereby notified that you may =ot disclose print, copy, disseminate, or otherwise use the information con=ained herein. If you are an employee or agent of the person(s) identified =bove to receive this communication and, as such, you have been authorized to deliver this communication to su=h person(s), you may disclose, print, copy, disseminate, or otherwise use =he information contained in this communication solely for the purpose of s=ch delivery. Unauthorized interception and/or use of this communication are/is strictly prohibited and may be pun=shable by law. If you have received this communication in error, please re=ly and notify the sender (only) of that fact and delete the communication,=including any and all attachments and enclosures, from your computer or other electronic device on which you=may have received this communication. =AO please note The information contained in this communication is<=r>confidential, may be attorney-client privileged, may constitute insid= information, and is intended only for the use of the addressee. It is =he property of JEE Unauthorized use, disclosure or copying of thiscommunication or any part thereof is strictly prohibited and may be un=awful. If you have received this communication in error, please notify =s immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destro= this communication and all copies thereof, including all attachments. =opyright -all rights reserved 11 EFTA_R1_01639202 EFTA02508239