EFTA02652537

From: jeffrey E. <[email protected]> Sent: Monday, April 17, 2017 10:20 PM To: Alan S Halperin Subject: Fwd: is it your position that a summary of the trust document=C2 with a note that says full document available upon request. and atta=hed to a tax return leaves it open to be deemed / =ot adequately disclosed ??! =orwarded messa e From: Thomas =urrin < <mailto > > Date: Mon, Apr 17, 2017 at 6:17 PM Subj=ct: RE: To: "jeffrey E." <[email protected] <mailto:jeevacation@gm=il.com» It is considered =9Cbest practice" to attach the complete trust document. You<=> avoid running afoul of ad=quate disclosure. Some agent could "deem =90 a brief summary of the trust to be inadequate. T=is issue is avoided by having the trust document attached. I'm sure Alan Hal=erin would agree. From: jeffrey =. [mailto:[email protected] <mailto:[email protected]> I Sent: Monday, April 17, 2017 5:58 PM To: Thomas Turrin Subject: Note that the Form 709 instructions also indicate th=t either a copy of the trust document or a brief summary of the trust provisions shoul= be attached to the 709 if there are any trust gifts reported. I ha=en't seen the IRS question the absence of this; but technically, t=e gift has not been "adequately disclosed" without this attachment, meaning that the statute of limitations never beg=ns to run on the return. please no=e EFTA_R1_01895844 EFTA02652537 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:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved =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 --001a11c111168b5e6d054d6431f0-- conversation-id 47223 date-last-viewed 0 date-received 1492467606 flags 8590195713 gmail-label-ids 7 6 remote-id 705991 2 EFTA_R1_01895845 EFTA02652538