EFTA02519700

From: Jeffrey Epstein <[email protected]> Sent: Tuesday, September 24, 2013 1:27 PM To: Ada Clapp; Melanie Spinella Subject: Re: Petition for Advisory Opinion you did not include the fact that sales tax has been paid, A0 already on the ites, and that he is actingin a non fircualrty capacity=A0 please re do On Mon, Sep 23, 2013 at 12:16 PM, Jeffrey Epstein [email protected]=m> wrote: this didn't incoude the last changes non fidiciary, , s=les tax already paid.etc On Mon, Sep 23, 2013 at 10:30 AM, Ada Clapp wrote: Jeffrey,=div> The form is set up so that you cannot save it as a docu=ent in editable format. Whomever is representing your client and submit=ing the Petition on his, her or its behalf will either need to (i) prin= out the form and type in the information (using an Attachment), or (ii) t=pe most of the information into the form online and save it as a PDF docum=nt (the form is not flexible enough to include the lengthly response to it=m 4, so your representative will need to use an Attachment). The PDF do=ument can be printed and submitted with the Attachment. I have attached what your client's representative m=y wish to use as responses to items 1-4. Item=5 addresses additional redacting you may wish for your client if you inclu=e any information other than what is on the attached draft Petition. Item 6 relates to reserving your client's right to =articipate in New York's Voluntary Disclosure and Compliance program w=th respect to the subject of the advisory opinion. As you may know, thi= program is designed to encourage taxpayers to come forward and declare un=aid taxes in exchange for NY not imposing penalties or bringing criminal c=arges. I do not know if there is any downside to reserving the ability =o participate in the VDC program-- but it would only apply to sales and us= tax relating to your client's having substituted tangible personal pr=perty into a grantor trust in exchange for other property. If your clie=t has not done this, perhaps it makes no sense to reserve this right. l=am not sure if it "looks suspicious" to check this box. Pe=haps Alan has a better feel for this? Your representative will also need to fi=1 out page 3 of the Petition which is the Power of Attorney and make the r=quired declaration. Ada Clapp EFTA_R1_01656005 EFTA02519700 =span style="font-size:7.5pt">Black Family Partners c/o Apollo Management 9 W 57th Street =span style="font-size:7.5pt">New York =Y 10019 =span st le="font-size:7.5 t"> hone: =RS Circular 230 Disclosure: Pursuant to IRS reg=lations, I inform you that any tax advice contained in this communication =including attachments) is not intended or written to be used, and cannot b= used by any person or entity for the purpose of (i) avoiding tax related =enalties imposed by any governmental tax authority, or (ii) promoting, mar=eting or recommending to another party any transaction or matter discussed=herein. I advise you to consult with an independent tax advisor on your pa=ticular tax circumstances. This communication, and any attachme=t, is for the intended recipient(s) only and may contain information that =s privileged, confidential and/or proprietary If you are not the intend=d recipient, you are hereby notified that further dissemination of this co=munication and its attachments is prohibited. Please delete all copies =f this communication and its attachments and notify me immediately that=you have received them in error. <=div> On Sep 23, 2013, at 6:53 AM, Jeffrey Epstein <[email protected]>= wrote: please fill out the advisory oinion form= I suggest using the concept that the setllor is excercising administra=itce powers =br> The information contained in this communication is confidential, may be =ttorney-client privileged, may constitute inside information, and is in=ended only for the use of the addressee. It is the property of Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any par= thereof is strictly prohibited and may be unlawful. If you have receiv=d this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachm=nts. copyright -all rights reserved 2 EFTA_R1_01656006 EFTA02519701 -- The infor=ation contained in this communication is confidential, may be attorney-=lient privileged, may constitute inside information, and is intended only for the use of the a=dressee. It is the property of Jeffrey Epstein Unauthorized use, disclosure or copying of thisc=r> communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, p=ease notify us immediately by return e-mail or by e-mail to [email protected], =nd destroy this communication and all copies thereof, including all attachm=nts. copyright -all rights reserved The information contained in this c=mmunication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the a=dressee. It is the property of Jeffrey Epstein Unauthorized use, di=closure or copying of this communication or any part thereof is strictl= prohibited and may be unlawful. If you have received this communication in error, p=ease notify us immediately by return e-mail or by e-mail to [email protected], =nd destroy this communication and all copies thereof, including all attachm=nts. copyright -all rights reserved 3 EFTA_R1_01656007 EFTA02519702