EFTA02617857

From: Barry J. Cohen Sent: Tuesday, September 19, 2017 2:28 PM To: Jeffrey E. Subject: "Tax Counsel"--PRIVILEGED AND CONFIDENTIAL As I thought about your advice on Joe V's use =f "Tax Counsel", I'm not sure I followed your logic.&nbs=; Joe V does not use this title on the tax return as he is not the prepare=. As to emails, if they pertain to legal advice, they will be privileged, and the IRS cannot see them. I guess you are saying to t=e extent his emails (a) say "tax counsel", (b) are not privile=ed, and (c) subpoenaed, the IRS could see that Joe characterizes himself a= "tax counsel" and insist on talking to him instead of one of our tax advisers who may be more appropriate. Right?<=o:p> Barry J. Cohen = I President and Speci=l Counsel Elysium Management,=LLC I 445 Park Avenue Suite 1401 New York, NY 10022&=bsp; I Tel Cell 1. <=c):p> <mailto &n=sp; 1 EFTA_R1_01820474 EFTA02617857